Anaheim City Council
May 17, 2022

ADDENDUM NO. 9 TO THE REVISED PLATINUM TRIANGLE

EXPANSION PROJECT FINAL SUBSEQUENT ENVIRONMENTAL
IMPACT REPORT NO. 339

Orangewood Avenue Improvements
From the Santa Ana River to the East of SR-57 and
Reorganization of Jurisdictional Boundaries

Lead Agency:

CITY OF ANAHEIM
200 South Anaheim Boulevard, Suite 162
Anaheim, California 92805
Contact: Andy Uk
714.765.5238
[email protected]

Prepared by:

MICHAEL BAKER INTERNATIONAL
5 Hutton Centre Drive, Suite 500
Santa Ana, California 92707
Contact: Mr. Alan Ashimine
949.472.3505

Revised April 2022

JN 159416

The format of this document is for double-sided printing to conserve natural resources.

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TABLE OF CONTENTS

1.0 INTRODUCTION ..................................................................................................................1-1

1.1 California Environmental Quality Act .................................................................................. 1-2

1.1.1 CEQA Requirements For Preparation Of An Addendum ........................................ 1-2

1.1.2 Type of CEQA Compliance Document and Level of Analysis ................................. 1-3

1.2 Project Summary ................................................................................................................. 1-5

1.3 Project Background ............................................................................................................. 1-6

1.4 Format and Content of this Addendum ............................................................................ 1-10

1.5 Environmental Checklist.................................................................................................... 1-10

1.6 Documents Incorporated by Reference .......................................................................... 1-111

2.0 PROJECT DESCRIPTION ........................................................................................................2-1

2.1 Project Location .................................................................................................................. 2-1

2.2 Environmental Setting ......................................................................................................... 2-1

2.3 Proposed Project ................................................................................................................. 2-4

2.3.1 Orangewood Avenue Right-of-Way Acquisition .................................................... 2-8

2.3.2 Bridge Structure Improvements............................................................................. 2-8

2.3.3 Trail and Stormwater Facility Improvements ........................................................ 2-8

2.3.4 Pipe Line Connection.............................................................................................. 2-9

2.3.5 Construction and Phasing ...................................................................................... 2-9

2.3.6 Santa Ana River Reorganization ............................................................................. 2-9

2.3.7 Project Approvals ................................................................................................. 2-17

3.0 ENVIRONMENTAL ANALYSIS ................................................................................................3-1

3.1 Aesthetics ............................................................................................................................ 3-3

3.2 Agriculture and Forestry Resources .................................................................................... 3-7

3.3 Air Quality ......................................................................................................................... 3-11

3.4 Biolo
gical Resources .......................................................................................................... 3-21

3.5 Cultural Resources ............................................................................................................ 3-27

3.6 Energy................................................................................................................................ 3-31

3.7 Geology and Soils .............................................................................................................. 3-35

3.8 Greenhouse Gas Emissions ............................................................................................... 3-43

3.9 Hazards and Hazardous Materials .................................................................................... 3-49

3.10 Hydrology and Water Quality ........................................................................................... 3-57

3.11 Land Use and Planning ...................................................................................................... 3-67

3.12 Mineral Resources ............................................................................................................. 3-71

3.13 Noise ................................................................................................................................. 3-73

3.14 Population and Housing .................................................................................................... 3-79

3.15 Public Services ................................................................................................................... 3-81

3.16 Recreation ......................................................................................................................... 3-85

3.17 Transportation .................................................................................................................. 3-87

3.18 Tribal Cultural Resources .................................................................................................. 3-93

3.19 Utilities And Service Systems ............................................................................................ 3-97

3.20 Wildfire ............................................................................................................................ 3-105

3.21 Mandatory Findings Of Significance................................................................................ 3-109

4.0 REFERENCES .......................................................................................................................4-1

5.0 PREPARERS AND CONTRIBUTORS ........................................................................................5-1

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6.0 ACRONYMS AND ABBREVIATIONS .......................................................................................6-1

LIST OF EXHIBITS
Exhibit 2-1 Regional Vicinity .................................................................................................................. 2-2 Exhibit 2-2 Site Vicinity .......................................................................................................................... 2-3 Exhibit 2-3 Site Plan ............................................................................................................................... 2-5 Exhibit 2-4 Platinum Triangle Implementation Plan – Orangewood Avenue Improvements ............... 2-6 Exhibit 2-5 Santa Ana River Reorganization Area ............................................................................... 2-10 Exhibit 2-6 Existing General Plan Land Use Map ................................................................................. 2-11 Exhibit 2-7 Proposed General Plan Land Use Map .............................................................................. 2-12 Exhibit 2-8 Existing Zoning Map .......................................................................................................... 2-13 Exhibit 2-9 Proposed Zoning Map ....................................................................................................... 2-14 Exhibit 2-10 Proposed Platinum Triangle Master Land Use Plan .......................................................... 2-18

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LIST OF TABLES
Table 1-1 SEIR No. 339 Addenda Summary Table ............................................................................... 1-7 Table 1-2 SCEA Summary Table .......................................................................................................... 1-9 Table 2-1 Santa Ana River Reorganization ........................................................................................ 2-15 Table 3.8-1 Consistency with SCAG’s 2020-2045 Regional Transportation Plan/ Sustainable Communities Strategy Goals ......................................................................... 3-45 Table 3.13-1 Maximum Noise Levels Generated by Construction Equipment ...................................... 3-74 Table 3.19-1 Landfills Summary ........................................................................................................... 3-101

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LIST OF APPENDICES
Appendix A Biological Resources Assessment
Appendix B Jurisdictional Delineation
Appendix C Phase I Environmental Site Assessment
Appendix D Basis of Design Report
Appendix E SB 18 Consultation Memorandum

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1.0 INTRODUCTION

Th
e City of Anaheim (City) proposes to widen Orangewood Avenue from a five-lan e roadway to a six-lane
d
ivided facility to provide expanded bicycle and pedestrian access from the Santa Ana River to just east of State Route 57 (SR -57) at the SR -57/Orangewood Avenue interchange. In general, the Orangewood Avenue Improvements P roject (“Proposed Project”) would incorporate an additional westbound through lane through the Project Site boundaries. The Proposed Project would also include a water pipe line connection in Orangewood Avenue right-of-way, generally beginning at Rampart Street and ending to the east at Eckhoff Street. In addition, the Proposed Project includes a change to the jurisdi ctional boundaries between the City of Anaheim and the City of Orange, west of the western levee of the Santa Ana River, north and south or Orangewood Avenue. This proposed reorganization includes amendments to the General Plan, Zoning Map, the Platinum Triangle Master Land Use Plan (PTMLUP), and other related documents to reflect the new City boundary and potential future use of the affected property.

The C
ity, as the Lead Agency , has prepared Ad dendum No. 9 (A ddendum) to the Final Subsequent Environmental Im pact Report No. 339 ( State Clearinghouse No. 2004121045) and Addendum No s. 1 through 8, and 10 (herein collectively referred to as SEIR No. 339).1 The Anaheim City Council certified and approved SEIR No. 339 for the Revised Platinum Triangle Expansion Project in 2010. This document refers to Revised Platinum Triangle Expansion Project, including all subsequent amendments analyzed by Addendum Nos. 1 through 8 and 10, as the “Approved Project.” The City has prepared this Addendum in accordance w ith the provisions of the California Environmental Quality A ct (CEQA) (California Public Resources Code [PRC] Sections 21000 et seq.); the State CEQA Guidelines (Title 14, California Code of Regulations [CCR] Sections 15000 et seq.); and the rules, regulations, and procedures for implementing CEQA as set forth by the City of Anaheim. In accordance with CEQA Guidelines Section 15367, the City is the lead agency with principal responsibility for considering the Proposed Project for approval.

Th
is introduction discusses:

1. The requirements of CEQA;

2. The primary purpose of an addendum to a previously ce rtified environmental im pact report (EIR);

3. The standards for adequacy of an ad dendum pursuant to the CEQA Guidelines;

4. SEIR No. 339;

5. The format and content of this Addendum;

6. The City’s processing requirements to consider the Proposed Project for approval;

7. An explanation of the Environmental Checklist provided in Section 3.0, Environmental Analysis; and,

8. A summary of the documents that this addendum incorporates by reference and points of contact for the Proposed Project.

1 One additional addendum and a Sustainable Communities Environmental Assessment (SCEA) were under preparation at the time of the preparation of this Addendum; refer to Table 1-1, SEIR No. 339 Addenda Summary Table.

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1.1 CALIFORNIA ENVIRONMENTAL QUALITY ACT

CEQA, a statewide environmental law contained in PRC Sections 21000–21177, applies to most public agency decisions which carry out, authorize, or approve actions that have the po tential to adversely affect the environment. The CEQA Guidelines allow for updating and using a previously certified EIR for projects that have changed or are different from the previous project or conditions analyzed in the certified EIR. In cases where changes or additions occur with no new significant environmental impacts, an addendum to a previously certified EIR may be prepared, consistent with CEQA Guidelines Section 15164. The City has prepared t his Addendum in accordance with Section 21166 of CEQA and Sections 15162 and 15164 of the CEQA Guidelines.

1.1.1 CEQA REQUIREMENTS FOR PREPARATION OF AN ADDENDUM

Section 15164(a) of the CEQA Guidelines states that “the lead agency or a responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred.” Pursuant to Section 15162(a) of the CEQA Gui delines, a subsequent EIR or Negative Declaration is only required when:

(1) S
ubstantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;

(2) Substantial changes occur with respect to the c ircumstances un der which the project is undertaken which will require major revisions of the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or

(3) New i nformation of su bstantial i mportance, w hich was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the negative declaration was adopted, shows any of the following:

(A) The project will have one or more significant effects not discussed in the previous EIR or
negative declaration;

(B) Significant effects previously examined will be substantially more severe than shown in the previous EIR;

(C
) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or

(D) Mitigation measures or alternatives which are
considerably different from those analyzed
in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

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The following describes the requirements of an addendum, as defined by CEQA Guidelines Section 15164:

a. The lead agency or responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred.

b. An ad dendum to an adopted ne gative declaration may be prepared if only minor t echnical changes or additions are necessary or none of the conditions described in Section 15162 calling for the preparation of a subsequent EIR or negative declaration have occurred.

c. An addendum need not be circulated for public review but can be included in or attached to the final EIR or adopted negative declaration.

d. The decision making body shall consider the add endum with the final EIR or adopted negative declaration prior to making a decision on the project.

e. A brief exp
lanation of the decision not to prepare a subsequent EIR pursuant to Section 15162 should be include d in an a ddendum to an EIR, the lead agency’s f indings on the project, or elsewhere in the record. The explanation must be supporte d by substantia l evidence.

If no
ne of these circumstances is present, and only minor technical changes or additions are necessary to update the previously certified EI R, an addendum may be prepared, consistent with CEQA Guidelines Section 15164. Based on the analysis and evaluation provided in this Addendum, no new significant impacts would occur because of the Proposed Project nor any substantial increase in the severity of any previously-ide
ntified significant environmental impact. In addition, no new information of substantial importance shows that mitigation measures or alternatives that were previously found infeasible or that are considerably different from those analyzed for SEIR No. 339 would substantially reduce one or more significant effects on the environment. Therefore, no conditions described in Section 15162 of the CEQA Guidelines has occurred. For this reason, an addendum is the appropriate document that w ill comply with CEQA requirements for the Proposed Project.

1.1.2 TYPE OF CEQA COMPLIANCE DOCUMENT

AND LEVEL OF ANALYSIS

The purpose of this Addendum is to analyze any potential differences between the impacts identified in SEIR No. 339 for the Approved Project and those that would be associated with the Proposed Project.

Pu
rsuant to the provisions of CEQA and the CEQA Guidelines, the City of Anaheim is the Lead Agency charged with the r esponsibility of d eciding whether to approve the Proposed Project. As part of i ts decision-ma
king process, the City is required to review and consider whether the Proposed Project would create new significant impacts or significant impacts that would be substantially more severe than those disclosed in SEIR No. 339. The Proposed Project would only trigger a dditional CEQA review beyond this Addendum if the Proposed Project creates new significant impacts or impacts that are more severe than those disclosed in SEIR No. 339 for the Approved Project. To use an addendum as the appropriate CEQA document for the Proposed Project, the City must find that major revisions of the SEIR No. 339 are not necessary and that none of the conditions described in CEQA Gu idelines Section 15162 calling for the preparation of additional CEQA documentation has occurred.

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CEQA G uidelines Section 1 5168(a) states that a Program EIR is appropriate for a series of actions, characterized as one large project, and are related either:

1. Geographically;

2. A logical parts [sic] in the chain of contemplated actions;

3. In connection with issuance of r ules, regulations, plans, or other general criteria to govern the conduct of a continuing program; or

4. As individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental effects which can be mitigated in similar ways.

As discussed in Section 2.0, the Proposed Project would allow for the widening and improvements to a segment of Orangewood Avenue . In addition, the Proposed Project includes a change to the jurisdictional boundaries between the City of Anaheim and the City of Orange. As detailed herein, the Proposed Project would not result in any new significant impacts that were not analyzed in SEIR No. 339, nor would the Project cause a su bstantial increase in the sev erity of any previously identified environmental impacts. The potential impacts associated with this Proposed Project would either be the same or less than those described in SEIR No. 339. In addition, there are no substantial changes to the circumstances, under which the City would undertake the Proposed Project that would result in new or more severe envi ronmental impacts than previously addressed in SEIR No. 339. Furthermore, this Addendum does not identify any new information regarding the potential for new or more severe significant environmental impacts been identified. Therefore, in accordance with CEQA Gui delines Section 15164 , this Addendum to the previously certified SEIR No. 339 is the appropriate environmental documentation for the Proposed Project. In acting on any of the approvals for the Proposed Project, the de cision-mak
ing body must consider the who le of the data presented in the SEIR No. 339 as augmented by this Addendum. In addition, the decision making body must consider all applicable mitigation from the Updated and M odified M itigation M onitoring Program No. 10 6C (also referred to as “MMP No. 106C” and “ Mitigation Measures from SEIR No. 339”) approved in conjunction with SEIR No. 339.

If the City finds that, pursuant to CEQA Guidelines Section 15162, no new effects could occur and no new mitigation is required, the City can approve the activity as being within the scope of SEIR No. 339.

As such, SEIR No. 339 clearly anticipated environmental impacts associated with projects such as the Proposed Project , and, thus, the SEIR was intended to serve as the Program EIR to be used in preparing CEQA compliance documentation for future projects.

CEQA Guidelines Se ction 1 5168(c) states that the decision making body must examine su bsequent activities undertaken pursuant to a Program EIR in li ght of the Program EIR to determine whether an additional envi ronmental docum ent must be prepared. Pursuant to CEQA Guidelines Section 15168(c)(4), “Where the subsequent activities involve site specific operations, the agency should use a written checklist or similar device to document the evaluation of the site and the activity to determine whether the environmental effects of the operation were covered in the Program EIR.”

Th
is A ddendum provides the environmental information necessary for the City to make an informed decision about the Proposed Project. The City has determined that an Addendum to SEIR No. 339 should be prepared, rather than a Supplemental or Subsequent EIR, based on the following facts:

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a. As demonstrated in the accompanying Environmental Checklist (see Section 3.0, Environmental Analysis), the Proposed Project would not r equire major revisio ns to the pr eviously certified SEIR No. 339 because the Project would not result in any new significant impacts to the physical environment nor w ould it create substantial increases in the severity of the environmental impacts previously disclosed in SEIR No. 339.

b. Subsequent to SEIR No. 339, no substantial changes occurred in the circumstances under which the Proposed Project would be undertaken.

c. Subsequent to SEIR No. 3 39, no new in formation of substa ntial importance has become available that was not known at the time SEIR No. 339 was prepared.

d. The Proposed Project’s discretionary actions would not result in any new or substantially more severe significant environmental impacts beyond those disclosed in SEIR No. 339. The reasonable consequence of the Proposed Project through approval of the various discretionary and ministerial a ctions would also not result in any new or substantially more severe significant environmental impacts beyond those disclosed in SEIR No. 339.

e. Subsequent to SEIR No. 339, no new mitigation measures or alternatives have been identified that were i nfeasible at the ti me the SE IR was certified and that would substantially reduce the Approved Project’s significant and unavoidable impacts to air quality, greenhouse gas emissions,
land use and planning, noise, and transportation and traffic.

f. Su
bsequent to SEIR No. 339, no new mitigation measures or alternatives that are considerably different from those analyzed in the SEIR have been identified to reduce the Approved Project’s significant a nd unavoidable impacts to air quality, greenhouse gas emissions, land use and planning, noise, and transportation and traffic.

g. Technical reports that evaluate the environmental impacts that could result from implementation of the Proposed Project were prepared: A ppendix A, Biological Resources Assessment; Appendix B, Jurisdictional Delineation; Appendix C, Phase I Environmental Site Assessment; and Appendix D, Basis of Design Report. Th ese te chnical reports do not identify any ne w impacts or substantial increases in impacts to the environment beyond those disclosed in SEIR No. 339.

Based on these facts, the City determined that an a ddendum to SEIR No. 339 is the a ppropriate ty pe of CEQA document to prepare for the Proposed Project. The pu rpose of this Addendum is to evaluate the Proposed Project’s level of impact on the envi ronment in comparison to the existing condition and Approved Project and SEIR No. 339.

1.2 PROJECT SUMMARY

Th
e Proposed Project would widen Orangewood Avenue from a five-lane ro adway to a six-lane d
ivided
facility to provide expanded bicycle and pedestrian access from the Santa Ana River to just east of State Route 57 (SR- 57) at the SR -57/Orangewood Avenue interchange. In general, the Project would incorporate an additional westbound through lane through the Projec t Site boundaries. The Project would also include a pipe line connection in Orangewood Avenue right -of-way, generally beginning at Rampart Street and ending to the east at Eckhoff Street . In addition, the Proposed Project includes a change to the jurisdictional boundaries between the City of Anaheim and the City of Orange, west of the

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western levee of the Santa Ana River , north and south or Orangewood Avenue. This proposed reorganization includes amendments to the General Plan, Zoning Map, the Platinum Triangle Master Land Use Plan (PTMLUP), and other related documents to reflect the new City boundary and potential future use of the affected property.

1.3 PROJECT BACKGROUND

In October 2010, the City approved the Revised Platinum Triangle Expansion Project, which included the following discretionary a pprovals: (1) Platinum Triangle Water Supply Assessment; (2) Anaheim General Plan Amendment No. 2008-0047
1; (3) amendments to The Platinum Triangle Master Land Use Plan ( PTMLUP), including The Platinum Triangle S tandardized Development Agreement Form; (4) amendments to Th e Platinum Triangle Mixed Use (PTMU) Overlay Zone; and (5) Zoning Reclassification No. 200 8-0022

2. SEIR No. 339, which was prepared to evaluate the potential impacts of the Revised Platinum Triangle Expansion Project, was certified by the Anaheim City Council on O ctober 26, 2010.

As a result of the land use approvals by the City, the development intensities of the PTMU Overlay Zone were increased to allow up to 18,909 residential units, 4,909,682 square f eet of commercial uses, 14,340,522 square feet of office uses, and 1,500,000 square feet of institutional uses. In addition to the increase in development intensity, the Revised Platinum Triangle E xpansion Project also identified upgrades to existing infrastructure to serve the proposed increased intensity o f lan d uses. T he upgrades included road way improv ements, sewer upgrades, two new wa ter wells, a new electrical substation, natural gas infrastructure improvements, and an additional fire station.

As part of i ts certification of SEIR No. 339, t he City Council adopted a Statem ent of Overridi ng Considerations to address significant and unavoidable environmental impacts that would result from implementation of the Re vised Platinum Triangle Expansion Project. These unavoidable i mpacts included the following:

• Air Quality
o Construction activities associated with the Approved Project would generate substantially more short-term air pollutants compared to the Adopted Master Land Use Plan and would continue to exceed South Coast Air Quality Management District’s regional significance thresholds.
o Implementation of the Approved Project would generate substantially more long- term air pollutants compared to the Adopted Master Land Use Plan and would continue to exceed South Coast Air Quality Management District’s regional significance thresholds. o Construction activities would potentially expose sensitive receptors to substantial pollutant concentrations of NO
X, CO, PM10, and PM2.5.
o Sensitive land uses within 500 feet of SR -57 and I-5 or within the recommended buffer distances to facilities emitting toxic air contaminants (TACs) may be exposed to substantial pollutant concentrations.

• Greenhouse Gas Emissions
o The Approved Project would generate substantially more greenhouse gas emissions compared to the Adopted Master Land Use Plan and cumulatively contribute to climate change impacts in California. However, the Approved Project would be consistent statewide and regional greenhouse gas reductions goals.

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• Land Use and Planning
o Some development pursuant to the Approved Project would not be compatible with the Southern California Gas Company’s existing microwave tower.

• Noise
o Build-out of the Approved Project woul d result in a substantial, permanent increase in ambient traffic noise levels within the vicinity of existing noise-sensitive receptors. o Noise-sensitive residential units proposed within the Platinum Triangle may be exposed to mobile- and stationary-source noise levels that exceed State and/or City standards. o Construction of the Approved Project would generate substantial levels of groundborne vibration and groundborne noise in the vicinity of vibration-sensitive land uses. o Development within the Platinum Triangle could result in a substantial temporary increase in noise levels in the vicinity of existing noise -sensitive land uses during construction activities.

• Transportation and Traffic
o Project-related trip generation would impact levels of service for the area roadway system.
o The Approved Project would increase traffic volumes on Caltrans facilities.

Nine addenda have been prepared to SEIR No. 339. Table 1-1, SEIR No. 339 Addenda Summary Table, provides a brief summary for each project within the Platinum T riangle for which the City Council approved an addendum. The City Council approved amendments to the land use assumptions in Revised Platinum Triangle Expansion Project, in conjunction with Addendum No. 2 -6, through the approval of amendments to the Anaheim General Plan, the Platinum Triangle Master Plan Use P lan, and PTMU Overlay Zone. These documents, as amended, currently permit development of up to 17,501 residential units; 4,782,243 square feet of commercial uses; 13,659,103 square feet of office uses, and 1,500,000 square feet of institutional uses. In addition, in 2020 a Sustainable Communities Environmental Assessment (SCEA) was approved for the Stadium District Sub -Area A Project, which creates the framework for the development of Sub -Area A of the Stadium District of the PTMU Overlay Zone pursuant to a Disposition and Development Agreement between the City of Anaheim and the Applicant and a Master Site Plan; refer to Table 1-2, SCEA Summary Table. It is acknowledged that t wo addenda were under preparation at the time of the preparation of this Addendum.

Table 1-1
SEIR No. 339 Addenda Summary Table

Addendum Title Project Summary
Addendum 1: Katella Avenue/
Interstate 5 Undercrossing
Improvements Project
April 2012
Widen Katella Avenue at the undercrossing with the I‐5 b etween Anaheim Way and Manchester Avenue and to create a fourth through lane of traffic in each direction of travel.

Maintain dual left ‐turn pockets a t bo th intersections. The project area spans approximately 1,0 00 feet along Katella Avenue, with an ar ea of disturbance encompassing approximately 1.95 acres.

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Addendum Title Project Summary
Addendum 2: Platinum
Gateway Project
December 2012
Develop a 4‐story wrap‐style residential building with 399 dwelling units, a 5‐story parking structure, and pu blic park on 7. 01 acres. Amend the Anaheim General Plan a nd the Platinum Triangle Master Land Use Plan ( PTMLUP) to inc rease the total number of dwelling un its to 18,988 dwelling units; reduce the commercial squa re foot age to 4,795,111 square feet; reduce the office square foot age to 14,131,103 square feet; and no change to institutional uses: 1,500,000 square feet.

Addendum 3: Platinum Vista
Apartments Project
October 2014
Develop a 5‐story wrap‐style residential apartment building with 389 units and a 6‐story parking str ucture (including one subterranean parking level). Amend the Anaheim General Plan and the PTMLUP to allow up to 19,027 dwelling units; 4,735,111 square feet of commercial uses; 14,131,103 square feet of office uses; and 1,500,000 square feet of institutional uses.

Addendum 4: Amended A‐
Town Metro Master Site
Plan August 2015
Construct eight neighborhood Development Areas rang ing in size from 3.1 acres to 5 .6 acres on the 43.2‐acre site. Develop between 1,400 and 1,746 residential dwelling units; up to 50,000 square feet of commercial/retail uses; and two public parks.

Addendum 5: Jefferson
Stadium Park Project
June 2016
Develop a mixed‐use community with 1,079 residential apartments; 14,600 square feet of retail uses; and a 1.11‐acre public park. Building 1 is a 5‐story wrap‐style building with 370 units; Building 2 is a 5‐story wrap‐style building with 376 units; Building 3 is a 4‐story podium building with 3 33 units and 14,600 square feet of retail space. Amend the Anaheim General Plan to relocate and combine two park sites into one park site. Amend the PTMLUP to allow for 18,909 dwelling units; 4,909,682 square feet of commercial uses; 14,340,522 square feet of office uses; and 1,500,000 square feet of institutional uses.

Addendum 6: LT Platinum Center
Development Project
September 2016
Mixed‐use development with 405 dwelling units; 433,000 gross square feet of commercial uses; a 200 ‐room hotel; 77,000 gross square feet of office uses. Amend the Anaheim General Plan and the PTMLUP to revise the district boundaries to change the LT Platinum Center site from the Gateway District to t he Stadium District; r educe the maximum dwelling un its to 17,348 un its; increase the maximum commercial us es to 4,782,243 square feet; reduce the maximum office space to 9,180,747 square feet; and remove the designation of a public park from the site.

Addendum 7: Gene Autry Way
and State College Boulevard
Improvements Project
March 2017
Widen Gene Autry Way from four lanes to six lanes with medians and storm drain and stormwater improvements; to widen the west side of State College Boulevard between Gateway Office and Artisan Court to accommodate a southbound right ‐turn lane and a third through‐lane; and to make improvements to the east side of the intersection of State College Boulevard at Gene Autry Way, which is the west entrance to Angel Stadium of Anaheim (Angel Stadium). Additionally, a new intersection on Gene Autry at Union Street would be constructed to provide access to planned development areas.

Addendum 8: Orangewood
Avenue Improvements (From
State College Boulevard to the
Santa Ana River) and Eastside of
State College Boulevard
Improvements (From
Orangewood Avenue to Artisan
Court)
March 2018
Widen Orangewood Avenue from State College Boulevard to Dupont Drive and from Dupont Drive to the Santa Ana River from four lanes to six lanes with the addition of right- turn lanes. Widen State College Boulevard to four lanes between Orangewood Avenue and Artisan Court; north of Artisan Court, the outside lane would become a right -turn pocket into the Angel Stadium of Anaheim parking lots. Road widening to add a new northbound right-turn lane at the Orangewood Avenue Intersection with Rampart Street.

Roadway improvements (sidewalk, reloc ated utilities, landscape planters, block walls, etc.) that were not considered in SEIR No. 339 are also analyzed.

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Addendum Title Project Summary
Addendum 9: Orangewood
Avenue Improvements
(From the Santa Ana River to
East of SR-57)
Subject Document
Subject Project: Widen Orangewood Avenue from a five ‐lane roadway to a six ‐lane divided facility to provide expanded bicycle and pedestrian access from the Santa Ana River to just east of State Route 57 (SR -57) at the SR -57/Orangewood Avenue interchange. The Proposed Project would also include a water pipe line connection in Orangewood Avenue right -of-way, generally beginning at Rampart Street and ending to the east at Eckhoff Street. In addition, the Proposed Project includes a change to the jurisdictional boundaries between the City of Anaheim and the City of Orange, west of the western levee of the Santa Ana River, north and south or Orangewood Avenue. This proposed reorganization includes amendments to the Anaheim General Plan, Anaheim Zoning Map, and PTMLUP, and other related documents to reflect the new City boundary and potential future use of the affected property.

Addendum 10: 710 E. Katella
General Plan, Zoning Map and
Platinum Triangle Master Land
Use Plan (PTMLUP)
Amendments (under preparation)
Amend the Anaheim General Plan , Anaheim Zoning Map , and PTMLUP to allow the development of up to 120 dwelling units at 710–818 East Katella Avenue and 1815 South Lewis Street. Development of the project site would be subject to the requirements of the Platinum Triangle Mix ed Use (PTMU) Overlay Zone, including but not limited to, subsequent City Council approval of a Development Agreement.

Addendum 11: OC V!be Project
General Plan, Zoning Map and
Platinum Triangle Master Land
Use Plan (PTMLUP)
Amendments (under preparation)
Amend the Anaheim General Plan , Anaheim Zoning Map , and PTMLUP to allow the development of proposed new homes, shopping, dining, entertainment, parks and open spaces around Honda Center and ARTIC transit center

Table 1-2
SCEA Summary Table
Addendum Title Project Summary
SCEA: Stadium District
Sub-Area A Project
September 2020
The Stadium District Sub -Area A Project creates the framework for the development of Sub-Area A of the Stadium District of the PTMU Overlay Zone pursuant to a Disposition and Development Agreement between the City of Anaheim and the Applicant and a Master Site Plan to allow development of Sub- Area of the Stadium District with up to the development intensities described.

Land Use Stadium District Sub-Area A Project
Residential (dwelling units) 5,175
Commercial (square feet) 1,750,000
Office (square feet) 2,700,000
Stadium (seats) 45,500
Public Parks (acres) 10-13
Fire Station One station on 1.5 acres

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1.4 FORMAT AND CONTENT OF THIS ADDENDUM

The following components comprise this Addendum:

a. Section 1.0, Introduction and Section 2.0, Project Description.

b. The completed Environmental Checklist and its associated analyses (Se ction 3 .0), which conclude that the Proposed Project would not result in any new significant environmental impacts or substantially increase the severity of envi ronmental impacts beyond the levels disclosed in SEIR No. 339.

c. Technical reports and other documentation that evaluate the Proposed Project and/or Project Site, which are appendices to this Addendum:

− Appendix A, Biological Resources Assessment (Michael Baker International, September 2017);

− Appendix B, Jurisdictional Delineation (Michael Baker International, January 2018);

− Appendix C, Phase I Environmental Site A ssessment (Michael Baker International, October 2017); and

− Appendix D, Basis of Design Report (Michael Baker International, March 2022).

1.5 ENVIRONMENTAL CHECKLIST

The City pr epared the Proposed Project ’s Envi ronmental Checklist per CEQA Guide lines Section 15063(d)(3) and Section 15168(c)(4). The CEQA Guidelines incl ude a suggested checklist to indicate whether the conditions set forth in its Section 15162, which would require a Subsequent or Supplemental EIR, are met, and whether there would be new significant impacts resulting from the Project not examined in SEIR No. 339. The checklist is found in Section 3.0 of this Addendum, along with an explanation and discussion of each significan ce de termination made in the checklist.

For this Addendum, four possible responses to ea ch of the individual envi ronmental issue areas are included on the checklist:

1. New Significant Impact. This response i ndicates w hen the currently Proposed Project has changed to such an extent that major revisions of SEIR No. 339 are required due to the presence of new significant environmental effects.

2. More Severe Impacts. This response indicates when the circumstances under which the currently Proposed Project is undertaken have changed to such an extent that major revisions of SEIR No. 339 are required because the severity of pr eviously identified significant effects would substantially increase.

3. New Ability to Substantially Reduce Significant Impact. This response indicates when new information of substantial importance that was not known and could not have been known with the exercise of reasonable diligence at the time SEIR No. 339 was certified indicates that there

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are new mitigation measures or alternatives available to s ubstantially reduce significant environmental impacts of the currently Proposed Project.

4. No Substantial Change from Previous Analysis. This response i ndicates that the currently Proposed Project would not create a new i mpact or substantially increase the severity of the previously identified environmental impact disclosed in SEIR No. 339.

The Environmen tal Checklist and accompanying explanation o f c hecklist responses provide t he information and analysis necessary to assess relative environmental impacts of the currently Proposed Project in the context of environmental impacts addressed in SEIR No. 339. In doing so, the City will determine the extent of additional environmental review, if any, for the currently Proposed Project.

1.6 DOCUMENTS INCORPORATED BY REFERENCE

CEQA Guidelines Se ctions 15150 and 15168(c)(3) and (d)(2) permit and e ncourage env ironmental documents to incorporate by reference other documents that provide relevant data. The following documents are incorporated by reference herein and are available for review upon request at the City of Anaheim (online via email to [email protected]
or by phone [ 714] 765-5139) or City of Orange
(online via email to [email protected] or by phone [714] 744-7220):

General Plan for the City of Anaheim: The General Plan for the City of Anaheim (Anaheim General Plan), dated May 2004, is a comprehensive, long-term plan that is a blueprint for the City of Anaheim’s growth and development. It covers issues ranging from the physical development of the jurisdiction, such as general locations, and extent of land uses and supporting infrastructure, to social concerns. It is organized into ten Elements (Land Use, Circulation, Green, Public Services and Facilities, Growth Management, Safety, Noise, Economic Development, Housing, and Community Design Elements) that address a wide range of subjects and provide goals and policies.

Anaheim General Plan and Zoning Code Update Environmental Impact Report No. 330, State Clearinghouse Number 2003041105: The Anaheim General Plan and Zoning Code Update Environmental Impact Report No. 330, State Clearinghouse Number 2003041105 ( Anaheim General Plan EIR), certified May 25, 2004, prepared by The Planning Center , addressed the environmental effects associated with the implementation of the Anaheim General Plan and City of Anaheim Zoning Code Update . It provided information pertaining to existing and future environmental settings within the City’s jurisdiction.

Anaheim Municipal Code: The Anaheim Municipal Code, current through Ordinance 6480, passed March 10, 2020, consists of regulatory, penal, and administrative ordinances of the City of Anaheim . These include standards intended to regulate land use, development, health and sanitation, water quality, public facilities, and public safety. Title 1 8 of the Anaheim Municipal Code, Zoning (Anaheim Zoning Code), is utilized to promote growth of the City in an orderly manner, and to promote and protect the public health, safety, peace, comfort, and general welfare in conformance with the Anaheim General Plan.

The Platinum Triangle Master Land Use Plan, August 2004, EDAW, Inc., as amende d: The Platinum Triangle Master Land Use Plan ( PTMLUP), dated August 2004, as amended , prepared by EDAW, Inc., serves as the blueprint for development within the Platinum Triangle . It establishes planning principles, applicable land use policies, allowable development intensities, and design guidelines.

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The Platinum Triangle Subsequent EIR No. 332, State Clearinghouse No. 2004121045: The Platinum Triangle Subsequent EIR No. 332, State Clearinghouse No. 2004121045 ( SEIR No. 332), dated 2005, prepared by The Planning Center, addressed the environmental effects associated with adopting the PTMLUP. It provided information pertaining to existing and future environmental settings within the City’s jurisdiction.

The Revised Platinum Triangle Expansion Project Subsequent Environmental Impact Report No. 339 , August 2010, The Planning Center : The Revised Platinum Triangle Expansion Project Subsequent Environmental Impact Report No. 339 ( SEIR No. 339 ), dated 2005, prepared by The Planning Center, addressed the environmental effects associated with the implementation of the Revised Platinum Triangle Expansion Project ( herein referenced as the Approved Project) in the City of Anaheim, California. The City of Anaheim propose d to increase the amount of residential, commercial, office, and institutional development intensities permitted in the Platinum Triangle. The Approved Project reduced the amount of office and commercial square footage and increased the number of residential units being requested as compared to the previous Platinum Triangle Expansion Project analyzed in Final SEIR No. 334. These modifications were made to improve the overall jobs/housing balance in the Platinum Triangle at buildout, encourage a full range of transit -oriented development opportunities for the Anaheim Regional Transportation Intermodal Center ( ARTIC), and reduce traffic impacts to the City of Orange. Since this time, the SEIR No. 339 has been amended as a result of eight subsequent addenda.

Platinum Triangle Implementation Plan: The City of Anaheim Public Works Department drafted the Platinum Triangle Implementation Plan (PTIP), originally drafted in August 2006, and subsequently updated most recently as Update No. 4, dated March 2016. The PTIP was based on the PTMLUP and associated documentation and includes descriptions of necessary street, sewer, and storm drain improvements to support PTMLUP development. The PTIP is intended as a planning tool for programming and funding decisions based on development patterns and intensity and foreseeable revenue streams available.

Orange General Plan: The Orange General Plan, dated March 2010, is the primary source of long-range planning and policy direction that is used to guide growth and change, and to preserve and enhance the quality of life within the City of Orange . It is organized into 11 Elements ( Land Use, C irculation and Mobility, Housing, Natural Resources, Public Safety, Noise, Cultural Resources and Historic Preservation, Infrastructure, Economic Development, Urban Design, and Growth Management Elements) that address a wide range of subjects and provide goals and policies.

Orange General Plan Program Environmen tal Impact Report : The Orange General Plan Program Environmental Impact Report (Orange General Plan P EIR), State Clearinghouse No. 2006031117, dated March 2010, prepared by EDAW, Inc. , addressed the environmental effects associated with the implementation of the Orange General Plan and City of Orange Zoning Code Update (Orange Zoning Code).

It provided information pertaining to existing and future environmental settings within the City’s jurisdiction.

Orange Municipal Code: The Orange Municipal Code, current through Ordinance No. 06 -20, adopted February 11, 2020 ( Supp. No. 42, 4/20) , consists of regulatory, penal, and administrative ordinances of the City of Orange. These include standards intended to regulate land us e, development, health and sanitation, water quality, public facilities, and public safety. Title 17 of the Orange Municipal Code, Zoning (Orange Zoning Code), is utilized to promote public safety, health, convenience, comfort, prosperity, or general welfare.

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2.0 PROJECT DESCRIPTION

2.1 PROJECT LOCATION

The Proposed Project is west of, the SR-57/Orangewood Avenue interchange, approximately 0. 63-mile east of I-5; refer to Exhibit 2-1, Regional Vicinity, and Exhibit 2 -2, Site Vicinity. Specifically, the Project Site is located in the City of Anaheim and the City of Orange, within Orange County Flood Control District (OCFCD) rights -of-way. The mu nicipal boundary for the c ities of Anaheim and Orange is along the western right-of-way boundary of the Santa Ana River. A lthough the Project Site is in both the City of Anaheim and the City of Orange, the City of Anaheim is the Project sponsor, and the Lead Agency for the purposes of CEQA. The SR-57/Orangewood Avenue interchange serves as a major gateway to the City of Anaheim and the Project would serve future increases in vehicles in the Project areas because of future development of Platinum Triangle in the City of Anaheim.

2.2 ENVIRONMENTAL SETTING

The Project Site and surrounding vicinity is located within an urbanized area of the c ities of Orange and Anaheim. Currently, the Project Site encompasses Orangewood Avenue, with five travel lanes (two westbound lanes and three eastbound lanes). In addition, the Proposed Project includes a change to the jurisdictional boundaries between the City of Anaheim and the City of Orange, west of the western levee of the Santa Ana River , north and south of Orangewood Avenue, from the southern City of Anaheim boundary to the SR-57. The Santa Ana River traverses the western portion of the Project Site and flows in a southern direction. The Santa Ana River Trail includes existing paved bike and pedestrian trail access along both sides of the Santa Ana River. Orangewood Avenue provides access to the trail from the west side of the Santa Ana River. At the Santa Ana River, Orangewood Avenue consists of an existing bridge structure constructed in 1966 and widened in 1981 (on the south side only). The trail under-crosses the Orangewood Avenue bridge structure in this location. To the east of the Orangewood Avenue bridge structure, the SR -57/Orangewood Avenue interchange, which includes the Orangewood Avenue Undercrossing bridge structure, is present.

Existing land uses near the Project Site consist of the following institutional and commercial uses:

• North: Upstream areas of the Santa Ana River are present to the north. SR -57 also continues north of the Project Site. Both City of Anaheim and City of Orange planning documents identify the Santa Ana River; however, the river in this location is located within the City of Orange. The Anaheim General Plan designates the San ta Ana River as Open Space; however, since it is not located within the City of Anaheim, the Anaheim Municipal Code does not identify a zone for this area. The Orange Zoning Code zones the Santa Ana River as Recreational Open Space (R-O), and the Orange General Plan designates the sit e as Open Space (OS). Angel Stadium of Anaheim [Angel Stadium]) and the associated parking lot are located to the north of the Project Site. The Anaheim General Plan designates this property for Mixed -Use Urban Core land us e, and it is within “PR” Public Recreational Zone and Sub-Area A of the Stadium District of the PTMU Overlay Zone of the Anaheim Zoning Map. C ommercial/office uses are present to the north of the eastern portion of the Project Site, within the City of Orange; the Orange General Plan designates these properties for Neighborhood Office Professional (NOP) land use at a maximum 0.5 FAR; and, they are within the Office Professional (O-P) Zone of the Orange Zoning Map.

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OR BLVD.

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Beach
San
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Santa
Ana
Anaheim
Fullerton
La
Habra
Brea
Cypress
Buena
Park
Yorba
Linda
Villa Park
Anaheim
Hills
Mission
Viejo
Lake
Forest
Laguna
Beach
Dana
Point
San Juan
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Laguna
Niguel
Orange
Huntington
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Alamitos
- Project Site
Project Site
PLATINUM TRIANGLE FIRE STATION NO. 12

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Exhibit 2-1
Regional Vicinity

NOT TO SCALE
12/21 | JN 186550

ORANGEWOOD AVENUE IMPROVEMENTS

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Exhibit 2-2
Site Vicinity

NOT TO SCALE
06/21 | JN 159416
Temporary Impacts
Permanent Impacts
Proposed City Boundary
Santa Ana River Reorganization Area
Source: Aerial - Google Earth Pro, June 2021.

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• East: Orangewood Avenue continues east of the Project Site. Commercial (office) uses are present to the east of the Project Site. These properties are within the City of Orange; the Orange General Plan designates these properties for NOP land use; and the properties are within the O- P and Commercial Professional (C-P) Zone of the Orange Zoning Map.

• South: The North Net Fire Training Facility is located southwest of the Project Site. This property is within the City of Anaheim; the Anaheim General Plan designates this property for Mixed-Use Urban Core land use; and , it is within the “PR” Public Recreational Zone and Sub -Area B of the Orangewood District of the PTMU Overlay Zoe of the Anaheim Zoning Map. The Santa Ana River flows south of the Project Site. The Anaheim General Plan designates this area for Open Space land use; as discussed above, the property is not within any identified zone on the Anaheim Zoning Map. This area is also within the R-O Zone of the Orange Zoning Map, and designated as OS in the Orange General Plan. SR -57 is also present to the south of the Project Site. Further southeast of the interchange, single- family residential uses (designated by the Orange General Plan as Low Density Residential 02-6 DU/AC [LDR] and zoned by the Orange Zoning Code as Single Family Residential 6,000 square feet [R-1-6]) are present.

• West: Orangewood Avenue continues west of the Project Site. Commercial, office, and industrial uses (Karl Strauss Brewing Company and the Orangewood Stadium Business Park) are present to the southwest of the Project Site. The Anaheim General Plan designates these properties for Mixed-Use Urban Code land -use; the properties are within the “C-G” General Commercial, “O -L” Low-Intensity Office, “I” industrial Zones, and Sub -Area A of the Orangewood District of the PTMU Overlay Zone of the Anaheim Zoning Map.

2.3 PROPOSED PROJECT

The City proposes to widen Orangewood Avenue from a five-lane r oadway to a six-lane d ivided facility to provide expanded vehicle, bicycle, and pedestrian access; refer to Exhibit 2 -3, Site Plan. The Proposed Project would incorporate an additional westbound through lane through the Project Site boundaries .

In order to widen the roadway, the Project would widen the existing Orangewood Avenue bridge structure over the Santa Ana River. Bridge widening improvements would involve widening the bridge approximately 30 to 35 feet on the north side to accommodate the proposed six travel lanes and associated bicycle lane/ sidewalk. The proposed total bridge length would be 348 feet, 6 inches. In addition, the Proposed Project includes a change to the jurisdi ctional boundaries between the City of Anaheim and the City of Orange, west of the western levee of the Santa Ana River, north and south or Orangewood Avenue. This proposed reorganization includes amendments to the General Plan, Zoning Map, PTMLUP, and other related documents to reflect the new City boundary and potential future use of the affected property.

SEIR No. 339 describes roadway improvements for potential intersection mitigation and fair-share improvements necessary for development of Platinum Triangle (referenced herein as the “Approved Project”. Upon certification of SEIR No. 339, the City of Anaheim prepared the Platinum Triangle Implementation Plan (PTIP). As discussed in Section 1.6, Documents Incorporated by Reference, the PTIP includes descriptions of necessary street, sewer, and storm drain improvements to support PTMLUP development. As such, the PTIP , and associated SEIR No. 339 , considered development of necessary street improvements, which included “Project 3D”, the widening of Orangewood Avenue from the City’s municipal boundaries to the SR -57 interchange; refer to Exhibit 2-4, Platinum Triangle Implementation Plan – Orangewood Avenue Improvements. The PTIP proposed these improvements to ensure

ORANGEWOOD AVENUE IMPROVEMENTS

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Exhibit 2-3
Site Plan

NOT TO SCALE
05/20 | JN 159416
N. ECKHOFF STREET

ORANGEWOOD AVENUE IMPROVEMENTS

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Exhibit 2-4
Plantinum Triangle Implementation Plan - Orangewood Avenue Improvements

NOT TO SCALE
11/17 | JN 159416
Source: City of Anaheim, Platinum Triangle Implementation Plan Orangewood Avenue Alignment East City Limit to 400’E/O SR-57, Sheets O-4 and O-5, dated October 2015.

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acceptable operations through the area and accommodate the Approved Project’s land use intensities.

Project 3D improvements (the Approved Project) addressed under SEIR No. 339 included widening the existing Orangewood Avenue bridge structure 24 feet, from five lanes (71 feet width) to six lanes (95 feet width). The Approved Project proposed widening with the add ition of a new westbound travel lane beginning at the City of Anaheim municipal boundary and trending east, ending just west of the SR - 57/Orangewood Avenue northbound off-ramp. The roadway widening would occur along a segment of the existing roadway, spanning approximately a half mile. Project 3D also proposed the installation of an approximately 70-foot long, three-foot-tall retaining wall within Caltrans jurisdiction along the north side of the Orangewood Avenue Undercrossing.

This Addendum identifies specific project changes that are necessary to accommodate the existing and proposed PTMLUP development intensities. These changes include additional widening of the bridge structure over the Santa Ana River, new property acquisition in OCFCD right-of-way, Santa Ana River Trail realignment, drainage facility relocation in the Santa Ana River, a water pipe line connection , and a change to the jurisdictional boundaries of land along the Santa Ana River more particularly described below. This Project, as proposed, woul d not construct the widening and retaining wall within Caltrans right-of-way, which were considered as part of the Approved Project. The specific Project design information, not known at the time of certification of the SEIR No. 339, is available at this time and detailed in Section 2.3.1, Orangewood Avenue Right-Of-Way Acquisition, through Section 2.3.4, Pipe Line Connection, below.

As referenced in the previous paragraph, the Proposed Project includes a realignment of a portion of the municipal boundary between the City of Anaheim and City of Orange along the Santa Ana River between approximately 1,000 feet south of Orangewood Avenue and approximately 1,000 feet south of Katella Avenue. The boundary adjustment would annex outside land from the City of Orange, into the City of Anaheim’s city boundaries. Prior to the review and approval of the reorganization by the Orange County Local Agency Formation Commission (LAFCO), the City is required to amend its General Plan and Zoning Map (“Reclassification) t o reflect the intended use of the subject properties (as described below, in Section 2.3.6, Santa Ana River Reorganization). This process has already been completed for a portion of the Angel Stadium property, referred to as Area 2A (Stadium Sliver) and has yet to be completed for the remainder of the area subject to the boundary reorganization; however, all properties are within the City’s sphere of influence and designated for certain land uses in the City’s General Plan. As shown below in Section 2.3. 6 Table 2 -1, Santa Ana River Reorganization, indicates the General Plan and Reclassifications that are a part of the Proposed Project. In addition to amendments to the General Plan Land Use Element and the Zoning Map, the Proposed Project would amend the City boundaries, as depicted in the General Plan and on the Zoning Map, to reflect the reorganization; and, amend the Platinum Triangle Master Land Use Plan, to expand the boundaries of the Platinum Triangle to incorporate the Proposed Project.

SEIR No. 339 Section 4.3.1, Location and Land Use, describes the Platinum Triangle as:
“The Platinum Triangle is an 820-acre area located within the City of Anaheim. The project area is comprised of the Angel Stadium of Anaheim, Honda Center, the Anaheim Stadium Metrolink/Amtrak Station, various light industrial uses, industrial parks, distribution facilities, offices, hotels, public recreation areas, and residential and supporting retail uses. The project area is bounded by the Santa Ana River to the eas t, the Anaheim City Limit to the south (approximately Orangewood Avenue and State College Boulevard), I -5 to the west, SR -57 to the east, and the Southern California Edison easement (approximately Cerritos Avenue) to the north.

The project area is accessible by motor vehicles from I- 5, SR-57, Katella Avenue, State College

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Boulevard, Orangewood Avenue, Lewis Street, and Anaheim Way. Additional access is provided through the Anaheim Stadium Metrolink/Amtrak station adjacent to the stadium.” The proposed realignment of a portion of the city boundary between the City of Anaheim and City of Orange, would maintain the eastern boundary of the Platinum Triangle as the Santa Ana River.

However, the Proposed Project would slightly increase the area of the Platinum Triangle to encompass the portion of the property currently within City of Orange that is the subject of this realignment. As described in Section 2.3.6 , the Proposed Project would amend the General Plan, Zoning Map, and Platinum Triangle Master Land Use Plan to reflect the anticipated future use of this area within the City of Anaheim. As described in this Addendum, the implementation of these amendments would result in nominal changes in land use in comparison to the existing use and future use of the s ubject area, as currently permitted by General Plan, Zoning, and Platinum Triangle Master Land Use Plan.

2.3.1 ORANGEWOOD AVENUE RIGHT-OF-WAY ACQUISITION

The Approved Project considered the widening of Orangewood Avenue from the City’s municipal boundaries to the SR -57 interchange within the existing roadway right -of-way; refer to Exhibit 2 -4.

However, to accommodate these improvements, the City would need to acquire new right-of-way from OCFCD. Construction activities associated with the Orangewood Avenue right-of-way acquisition would temporarily impact an approximately 1.12-acre area of the Santa Ana River. Temporary activities occurring within this area would include placement of shoring, driving of foundation piles, construction of bent caps and piers, construction of the bridge, scour countermeasure (e.g., modified bridge footings or placement of a permeable articulated concrete block [ACB] mat, or other alternative), and relocation of an existing drainage outfall.

Although the Project would require some areas of permanent take within the Santa Ana River, the Project would not require any permanent right -of-way acquisition of private properties. Other than those improvements within the Santa Ana River, all permanent improvements would occur within existing roadway rights-of-way.

2.3.2 BRIDGE STRUCTURE IMPROVEMENTS

The Approved Project considered widening the bridge structure by 24 feet and restriping the roadway to accommodate an additional westbound travel lane. However, the Proposed Project would widen the north side of the Orangewood Avenue bridge structure over the Santa Ana River approximately 30 to 35 feet to accommodate the bicycle and sidewalk facilities . The proposed total bridge length would be 348 feet, 6 inches. The Proposed Project would expand six existing bridge pier walls and install five new debris noses to support the proposed bridge widening.

2.3.3 TRAIL AND STORMWATER FACILITY IMPROVEMENTS

The Approved Project did not specifically consider necessary improvements in order to maintain existing access to the Santa Ana River Trail and stormwater facilities. I n order to accommodate the new bridge widening, the Santa Ana River Trail would need to be realigned along the western portion of the Santa Ana River, and reconstructed in -place at the eastern portion. New retaining walls would be installed along the eastern portion of the trail under the widened Orangewood Avenue bridge structure. Also, the existing drainage facility located at the eastern portion of the Santa Ana River would need to be relocated

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slightly north of the existing location; as depicted on Exhibit 2‐3.  Existing access to the Santa Ana River Trail from Orangewood Avenue would be maintained.

2.3.4 PIPE LINE CONNECTION

The  Approved  Project  considered  construction  of  new  subsurface  water  facilities  in  Orangewood Avenue right‐of‐way (a proposed 16‐inch water pipe line) as far east as the City’s municipal boundary (PTIP Project 3C).  However,  the Approved Project did not consider extension  of this 16‐inch pipe line through the Project site.  The  Proposed Project would  construct a new 16‐inch ductile iron water pipe line  in  Orangewood  Avenue  right‐of‐way,  generally  beginning  at  the  City’s  municipal  boundary  and ending to the east at Eckhoff Street.  This new pipe line would connect the proposed 16‐inch water pipe line, being constructed  as PTIP Project 3C, to the exi sting 10‐inch water pipe line in the City of Orange (in  Eckhoff  Street  right‐of‐way).  The   new  pipe  line  connection  would  enhance  the  City  of  Orange’s existing water system, providing redundancy should failure arise in other areas of the system.  The water line would affect an approximately half‐mile
segment of Orangewood Avenue as shown on Exhibit 2‐3.

2.3.5 CONSTRUCTION AND PHASING

Construction  activities  associated  with  the  Proposed  Project  would  occur  following  acquisition  of  the required parcels.  The Project proposes a 12‐month construction period (anticipated to begin July 2023 and completed by June 2024).

2.3.6 SANTA ANA RIVE R REORGANIZATION

The Project proposes to reorganize land within the Project area through a municipal boundary adjustment within the Project limits to annex land outside of the City limits (currently in the City of Orange) into the City  of  Anaheim,  incorporating  properties  within  the  City’s  sphere  of  influence  and  expanding  the boundaries  of  Platinum  Triangle;  see  Exhibi
t  2‐5,  Santa  Ana  River  Reorganization  Area.  The  proposed boundary adjustment would require review and approval by the LAFCO.  Prior to review and approval of the  boundary  adjustment  by  the  LAFCO,  the  City  is  required  to  amend  the  land  use  designations  and zoning on the properties proposed for annexation to reflect their intended uses.  As such, Table 2‐1, Santa Ana River Reorganization, shows the existing and proposed land use designations and zoning for the areas proposed for annexation.

Area 1A and Area 1

As shown on Exhibit 2‐5, “Area 1A North Net Sliver” (Area 1A) and “Area 1 OCFCD Excess” (Area 1) are located  south  of  Orangewood  Avenue  and  bound  by  North  Net  Training  Center  (2400  Orangewood Avenue) to the west and the Santa Ana River Trail to the east.  The proposed reorganization would realign a  sliver  of  the  North  Net  Training  Center  property  to  allow  the  entire  parcel  to  be  located  within  the Anaheim  city  limits.   This  sliver  would  continue  to  provide operational  use  for  the  North  Net  Training
Center and would be incorporated with the proposed acquisition.  North Net is currently in the process of acquiring property from OCFCD for its continued use.

As shown on Exhibit 2‐6, Existing General Plan Land Use Ma p, and Exhibit 2‐7, Proposed General Plan Land
Use Map, the General Plan land use designation for Areas 1 and 1A would be amended from Open Space to Mixed‐Use Urban Core.  As shown on Exhibit 2‐8, Existing Zoning Map, and Exhibit 2‐9, Proposed Zoning Map, Areas 1 and 1A would be zoned “PR” Public Recreational Zone and Sub Area B of the

ORANGEWOOD AVENUE IMPROVEMENTS
Exhibit 2-5
Santa Ana River Reorganizational Area
10/2021 JN 159416

ORANGEWOOD AVE

RAMPART
ST

DOUGLASS RD

DUPONT DR
TO
W

NE CENTRE PL
AREA 2

OCFCD EXCESS
AREA 2A

STADIUM SLIVER
(Not a part of the
project)
AREA 1

OCFCD EXCESS
AREA 1A

NORTH NET
SLIVER
AREA 3

CITY OF

ORANGE ROAD
City of
Anaheim
City of
Orange
North Net
Angel Stadium
0 800400
Feet
Key to Features
57 3
2A
2 1A
1 Area
Project Site
City Boundary
Proposed City Boundary
Parcel Boundary

ORANGEWOOD AVENUE IMPROVEMENTS

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Exhibit 2-6
Existing General Plan Land Use Map
10/2021 JN 159416

ORANGEWOOD AVENUE IMPROVEMENTS

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Exhibit 2-7
Proposed General Plan Land Use Map
10/2021 JN 159416

ORANGEWOOD AVENUE IMPROVEMENTS

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Exhibit 2-8
Existing Zoning Map
10/2021 JN 159416

ORANGEWOOD AVENUE IMPROVEMENTS

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Exhibit 2-9
Proposed Zoning Map
10/2021 JN 159416

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Orangewood Avenue Improvements

Final | March 2022 2-15 Project Description
Table 2-1
Santa Ana River Reorganization

Area Subject to Reorganization
Existing
General Plan
Designation
Existing Zoning
Proposed
General Plan
Designation
Proposed Zoning
Area 1 OCFCD Excess

Area 1A North Net Sliver
Open Space None Mixed-Use
Urban Core
Public Recreational (PR)
Zone

Platinum Triangle Mixed-
Use (PTMU) Overlay Zone

Orangewood District Sub
Area B
Area 2 OCFCD Excess Open Space None Park Public Recreational (PR) Zone
Area 3 City of Orange Road Primary Arterial Not Applicable Primary Arterial (No Change) Not Applicable
Remaining Area Open Space None Open Space
(No Change) Open Space (OS) Zone

Orangewood District of the Platinum Triangle Mixed Use (PTMU) Overlay Zone. This is the same General Plan land use designation and zoning as the existing North Net Training Center.

The Mixed-Use Urban Core designation allows a mix of uses including residential, commercial, services, hotel, and professional office uses in a high -quality environment. The focus of this designation is on creating a pedestrian -friendly environment, including increased connectivity and community gathering spaces. Uses may mix in a vertical, horizontal, or multi-use pattern. Stand-alone uses within a multi-use project need to integrate into an overall project design and connected to other adjoining uses by plazas, promenades, and landscaped corridors; and, should include common architectural themes and signage.

Typical residential uses could include stacked flats, live -work units, and artist-style lofts. The maximum density for the residential component of mixed-use development is up to 100 dwelling units per acre. The maximum floor area ratio for the nonresidential component of mixed-use development is 3.00.

The intent of the PTMU Overlay Zone is to provide opportunities for well-designed development projects that combine residential with non -residential uses. The non -residential uses include office, retail, business services, personal services, public spaces and uses, and other community amenities within the portions of the Platinum Triangle designated with the Mixed -Use, Office High and Office Low land use designations in the Anaheim General Plan, and consistent with the policy direction in the Anaheim General Plan. The PTMU Overlay Zone has the following major objectives:

• Create a unique integrated, walkable urban environment that encourages pedestrian activity and reduces dependence on the automobile for everyday needs, through a connected streetscape that is attractive, safe, and engaging;
• Develop an overall urban design framework to ensure that the appearance and effects of buildings, improvements, and uses are harmonious with the character of the area in which they are located;
• Encourage compatibility between residential, office, commercial and sports entertainment uses; • Reinforce Transit Oriented Development (TOD) opportunities around the Anaheim Regional Transportation Intermodal Center (ARTIC) station;

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
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Final | March 2022 2-16 Project Description
• Maintain and enhance connectivity and linkages with convenience services, dining, retail, and recreation facilities within walking distance, by providing ground floor commercial uses in key locations;
• Provide a mix of housing types;
• Create great long-lasting neighborhoods that maintain value through buildings with architectural qualities that create attractive street scenes;
• Provide a variety of open space, including private, recreational-leisure areas and public parks; • Create a balance of landscape and architecture by providing sufficient planting space; and • Encourage parking solutions that are incentives for creative planning and sustainable neighborhood design.

The proposed re classification to the PTMU Overlay Zone would not increase the maximum permitted development above the 321 dwelling units previously analyzed in the SEIR No. 339 for Sub Area B of the Orangewood District of the PTMU Overlay Zone. In the event the subject properties, including the existing North Net Training Center, are considered for future development, the maximum development intensity of 321 dwelling units would apply to all of Sub Area B. However, this is not anticipated in the near future at this time.

Area 2

“Area 2 OCFCD Excess” (Area 2) is located north of Orangewood Avenue and consists of a regional bike trail and landscaping. The City is currently studying the potential to purchase Area 2 from the OCFCD for the development of a park as part of a future, separate and independent project . A General Plan Amendment and Zoning Map Amendment would be required to change Area 2 land use designation from Open Space to Parks and zoning to the “PR” Public Recreational Zone; refer to Exhibits 2 -6 through 2-9.

The Parks designation allows for active and passive recreational uses such as parks, trails, athletic fields, interpretive centers, and golf courses. The Parks land designation permits a maximum floor area ratio of

0.10. The PR zone implements the Parks land use designation. The intent of the PR z one is to establish for the benefit of the health, safety, and general welfare of the citizens of Anaheim and its visitors, a zone to preserve, regulate, and control the orderly use and enjoyment of City-owned properties and facilities and adjacent private property. Properties within the purview of the PR z one include: (a) City -owned properties, whether the same is exclusively occupied by the City or is used by others on the basis of some agreement with or concession by the City; and (b) adjacent private propert ies, whose use s and development have an impact on the use and enjoyment of City-owned properties and facilities.

Area 3 and Remaining Area

The General Plan Circulation Element would continue to designate Area 3, Orangewood Avenue, as a Primary Arterial. The General Plan Land Use Element would continue to designate the remaining area north and south of Orangewood Avenue, between the Proposed City Boundary and Areas 1, 1A, 2 and 2A, for Open Space land use. The Open Space land use designation applies to properties intended to remain in natural open space; utility easements that will provide recreational and trail access to Anaheim’s residents; heavily landscaped freeway remnant parcels, and land areas surrounding major water features.

The Proposed Project would apply the OS Zone to this area . The OS Zone is the implementing Zone for the General Plan Open Space land use designation and permits a maximum floor area ratio of 0.10.

Currently, the City of Anaheim Zoning Map does not include this area within any Zone.

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Orangewood Avenue Improvements

Final | March 2022 2-17 Project Description
The changes to the City jurisdictional boundaries would require amendments to the General Plan Land Use Element, Zoning Map, and Platinum Triangle Master Land Use Plan ; refer to Exhibit 2 -10, Proposed Platinum Triangle Master Land Use Plan.

2.3.7 PROJECT APPROVALS

This Addendum to SEIR No. 339 serves as the primary CEQA environmental document for all actions associated with the Proposed Project, including all discretionary approvals requested or required to implement the Project. The actions and/or approvals by the City of Anaheim to implement the Project include, but are not limited to, the following:
• Approval of the Addendum No. 9 to the Revised Platinum Triangle Expansion Project Subsequent Environmental Impact Report No. 339;
• Right-of-Way Construction Permit. The City is requesting issuance of a right-of-way construction permit for construction activities.
• Acquisition of Property. The City is requesting approval for acquisition of OCFCD property for construction activities and Project implementation.
• General Plan Amendment. The City is requesting to amend the City boundaries as depicted in the General Plan to annex land outside of the City limits into Anaheim and designate the annexed properties, as applicable, for their anticipated future land use. • Zoning Map Amendment (“Reclassification”). The City is requesting to amend the City boundaries as depicted on the Zoning Map to annex land outside of the City limits into Anaheim and reclassify the annexed properties to the implementing zones for their General Plan land use designations.
• Platinum Triangle Master Land Use Plan Amendment. The City is requesting to expand the boundaries of the Platinum Triangle to incorporate land proposed for annexation into the Anaheim City limits.
• Property Tax Exchange Approval. The City is requesting approval for the exchange of property tax revenues as sociated with the land proposed for annexation between the City of Anaheim and City of Orange.
• City Boundary Reorganization approval/recommendation. • District 5 Incorporation Approval.

Approvals by other agencies would include, but may not be limited to, the following:
• City of Orange Encroachment Permit;
• City of Orange Property Tax Exchange Approval;
• Caltrans Encroachment Permit;
• City of Orange Property Tax Exchange Approval;
• U.S. Army Corps of Engineers Section 404 Nationwide Permit 14 - Linear Transportation Projects and Section 408 Permit;
• California Department of Fish and Wildlife 1602 Streambed Alteration Agreement;

ORANGEWOOD AVENUE IMPROVEMENTS

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Exhibit 2-10
Proposed Platinum Triangle Master Land Use Plan

NOT TO SCALE
10/21 | JN 159416

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Orangewood Avenue Improvements

Final | March 2022 2-19 Project Description

• Regional Water Quality Control Board Section 401 Water Quality Certification; • City and Regional Water Quality Control Board approvals of a Stormwater Pollution Prevention Plan (SWPPP); and
• Orange County Local Agency Formation Commission (LAFCO) City Boundary Reorganization Approval.

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
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Final | March 2022 2-20 Project Description
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Final | March 2022 3-1 Environmental Analysis

3.0 ENVIRONMENTAL ANALYSIS

ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED

The environmental factors checked below would be potentially affected by this Project, involving at least one impact that is a “Potentially Significant Impact,” as indicated by the checklist on the following pages.

Aesthetics Mineral Resources
Agriculture and Forestry Resources  Noise
 Air Quality Population and Housing
Biological Resources Public Services
Cultural Resources Recreation
Energy  Transportation
 Geology and Soils Tribal Cultural Resources
 Greenhouse Gas Emissions  Utilities and Service Systems  Hazards and Hazardous Materials Wildfire
 Hydrology and Water Quality Mandatory Findings of Significance  Land Use and Planning

On the basis of this initial evaluation:

 I find that the Proposed Project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
 I find that although the Proposed Project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.  I find that the Proposed Project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
 I find that the Proposed Project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.
 I find that although the Proposed Project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier ENVIRONMENTAL IMPACT REPORT or NEGATIVE DECLARATION pursuant t o applicable standards, and (b) have been avoided or mitigated pursuant to that earlier ENVIRONMENTAL IMPACT REPORT or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the Proposed Project, nothing further is required.

Signature Date

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Final | March 2022 3-2 Environmental Analysis
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Final | March 2022 3-3 Environmental Analysis

3.1 AESTHETICS

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Have a substantial adverse effect on a scenic vista?  b. Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic
buildings within a state scenic highway?

c. Substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from
publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with
applicable zoning and oth er regulations governing
scenic quality?

d. Create a new source of substantial light or glare, which would adversely affect day or nighttime views in the
area?


a) Would the project have a substantial adverse effect on a scenic vista?

Previous Significance Determination: The Initial Study for SEIR No. 339 determined that the Approved Project does not contain any scenic vistas that are officially recognized at a local, State, or Federal level.

The Initial Study concluded that impacts to scenic vistas would be less than significant and no mitigation measures were necessary. Because the Initial Study considered these impacts less than significant, they were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: Generally, scenic vistas are defined as a view of undisturbed natural lands exhibiting a unique or unusual feature that comprises an important or dominant portion of the viewshed.

Scenic vistas may also be represented by a distant view that provides visual relief from less attractive views of nearby features. Other designated Federal and State lands, as well as local open space or recreational areas, may also offer scenic vistas if they represent a valued aesthetic view within the surrounding landscape of nearby features. The Anaheim General Plan Land Use Element designates the Santa Ana River, the Hill and Canyon Area, and open space areas as scenic resources and encourages the preservation and protection of these areas. The Orange General Plan Natural Resources Element designates the Santiago Hills II and Irvine Lake, grassy valleys, rugged hillsides, rock outcroppings, and winding canyons present in the east Orange portions of its planning area as scenic resources and encourages the preservation and protection of these areas while still allowing development to occur.

The Proposed Project would occur within a highly urbanized area of Anaheim and Orange where existing development blocks public views to Anaheim’s Hill and Canyon Area and open space and Orange’s scenic resources (Santiago Hills II and east Orange resources). Project construction activities associated with the trail improvements and bridge improvements at Orangewood Avenue as it crosses the Santa Ana River would in volve short -term visual impacts to public views of the River (an Anaheim -designated scenic resource) due to the presence of construction equipment and heavy -duty vehicles, materials and debris piles, and other general construction activities. However, these impacts would be temporary and limited

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
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Final | March 2022 3-4 Environmental Analysis
to the Project’s construction duration. Further, Project improvements would occur along a segment of the Santa Ana River where channelization has already heavily degraded significant natural features.

The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of these sites would be subject to CEQA and analyzed on a per project basis . However, given that the permitted type and intensity of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact to aesthetics would not increase from that identified in SEIR No. 339.

Therefore, the Proposed Project would not obstruct views of the Santa Ana River over the long term.

Impacts to scenic vistas would be less than significant, and the level of impact would not substantially increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

b) Would the project substantially damage scenic resources including, but not limited to, trees, rock outcroppings, and historic buildings within a State scenic highway?

Previous Significance Determination: The Initial Study for SEIR No. 339 determined that the Platinum Triangle is not located within the viewshed of a State scenic highway . The closest Officially Designated State Scenic Highway to the Platinum Triangle is SR-91 from SR-55 to east of the City’s limit near Weir
Canyon. The Initial Study concluded that impacts to scenic resources would be less than significant since the Platinum Triangle is not visible from SR -91
, nor is SR-91
visible from the Platinum Triangle. Because
the Initial Study considered these impacts less than significant, they were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: According to the Californ ia Department of Transportation’s (Caltrans) California Scenic Highway Mapping System , the Project area does not contain any officially -designated scenic highways.2 As indicated in the Initial Study for SEIR No. 339, the nearest eligible scenic highway is SR-91, which is located more than four miles northeast of the Project Site. The Project Site does not provide views of SR-91 due to intervening topography, structures, and vegetation. Due to the absence of designated scenic highways in the Project Site vicinity, no impact would occur , and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

c) Would the project substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality??

This impact threshold was modified by the Governor’s Office of Planning and Research (OPR) in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements.

Specifically, c onsideration of degradation of character or quality was clarified for urbanized areas.

2 California Department of Transportation Website, California Scenic Highway Mapping System , http://www.dot.ca.gov/hq/LandArch/16_livability/scenic_highways/index.htm, Accessed October 11, 2017.

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
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Final | March 2022 3-5 Environmental Analysis
Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 on page 5.1-9 of SEIR No. 339.

Pr
evious Significance Determination: SEIR No. 339 classifies the Platinum Triangle as an area transitioning from light industrial to mixed use development in accordance with the adopted PTMLUP .

Despite the increased intensity of residential and nonresidential land uses, SEIR No. 339 found that compliance with provisions of the adopted PTMLUP would ensure the individual projects are compatible with existing and future land uses within the Platinum Triangle. SEIR No. 339 concluded that impacts to visual character and quality would be less than significant with the incorporation of SEIR No. 332 Mitigation Measure (MM) 5.1-1,
which requires a shade analysis for shadow-sensitive properties.

Project‐Specific Analysis: As discussed in Section 2.0 , the Project Site consists of paved asphalt roadway right-of-way and a regional bike trail, surrounded by channelized portions of the Santa Ana River, SR-57, commercial, office, institutional, and residential land uses. Based on the Project’s location within an urban environment, the Proposed Project would not substantially degrade the existing visual character or quality of public views of the site and its surroundings. The following discussion analyzes the Proposed Project’s potential to conflict with applicable zoning and other regulations governing scenic quality.

No applicable municipal or other regulations governing scenic quality apply to the Project Site; refer to Section 3.11, Land Use and Planning. The Anaheim General Plan does not identify Orangewood Avenue as a Scenic Expressway and the Orange General Plan does not identify it as a Viewscape Corridor. Limited permanent visual changes associated with the proposed roadway widening and associated infrastructure and Santa Ana River reorganization would occur because of the Proposed Project. As such, once construction is complete, the road way widening and realignment of jurisdictional boundaries of land along the Santa Ana River would not significantly impact the visual character of the Project Site. In addition, the Proposed Project would not involve aboveground features which are substantially different from existing conditions. Visible changes associated with the Proposed Project would include additional hardscapes associated with the widened Orangewood Avenue bridge structure . The Proposed Project would lengthen f ive existing bents situated along the Santa Ana River bottom to accommodate the widening. In addition, the Project would realign a portion of the Santa Ana River Trail along the western portion of the Santa Ana River, and reconstruct in -place at the eastern portion. The Proposed Project would install n ew trail walls under the widened Orangewood Avenue bridge structur e. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of these sites would be subject to CEQA and analyzed on a per project basis. However, given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact to groundwater supplies would not increase from that identified in SEIR No. 339.

Overall, these features would occur within a heavily disturbed segment of the River that has been subject to channelization and is generally devoid of natural resources; refer to Section 3. 4, Biological Resources.

Based on the similarity of these features to existing conditions, permanent visual changes associated with the Proposed Project would not significantly impact the visual character of the Project Site . The Project also would not result in shade and shadow impacts to adjacent properties and SEIR No. 332 MM 5.1-1 is not applicable. Less than significant impacts would occur in this regard, and the level of impact would not substantially increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

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Final | March 2022 3-6 Environmental Analysis
d) Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?

Previous Significance Determination: According to the Initial Study for SEIR No. 339 , buildout of the PTMLUP would introduce numerous new sources of nighttime illumination, including those related to buildings, pedestrian walkways, parking areas, park facilities, and roadways. The Initial Study for SEIR No. 339 concluded that compliance with the provisions of the PTMLUP and SEIR No. 33 2 MM 5.1-1 would reduce light and glare impacts to less than significant with mitigation.

Project‐Specific Analysis: To accommodate widening at the Orangewood Avenue Santa Ana River crossing, the Proposed Project would realign/reconstruct portions of the Santa Ana River Trail located within OCFCD/City of Orange jurisdiction . The Proposed Project would relocate existing street lights occurring at the westerly Orangewood Avenue/SR -57 signalized intersection to accommodate the new travel lane. The Proposed Project’s light sources would be installed to safeguard public safety of motorists, pedestrians, and bicyclists traveling along the affect ed segment of Orangewood Avenue and trail users. Lighting would be similar to existing lighting sources on-site and along Orangewood Avenue and designed to avoid light-spillage onto surrounding uses. SEIR No. 332 MM 5.1-1 requires preparation of a shade/shadow analysis for future development projects where adjacent uses are shadow sensitive.

As a roadway widening and annexation project, SEIR No. 332 MM 5.1-1 would not be applicable. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of these sites would be subject to CEQA and analyzed on a per project basis. However, given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact to aesthetics would not increase from that identified in SEIR No. 339. For these reasons, impacts concerning light or glare would be less than significant, and the level of impact associated with the Proposed Project would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

3.1.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

SEIR No. 332 mitigation measures are not applicable to the Proposed Project.

Mitigation Measures from SEIR No. 339

SEIR No. 339 mitigation measures are not applicable to the Proposed Project.

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
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Final | March 2022 3-7 Environmental Analysis

3.2 AGRICULTURE AND FORESTRY RESOURCES

In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site
Assessment Model (1997) prepared by the California
Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection rega rding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols
adopted by the California Air Resources Board. Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the Farmland
Mapping and Monitoring Program of the California
Resources Agency, to non-agricultural use?

b. Conflict with existing zoning for agricultural use, or a Williamson Act contract? 
c. Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code
section 12220(g)), timberland (as defined by Public
Resources Code section 4526), or timberland zoned
Timberland Production (as defined by Government
Code section 51104(g))?

d. Result in the loss of forest land or conversion of forest land to non-forest use? 
e. Involve other changes in the existing environment,
which, due to their location or nature, could result in conversion of Farmland, to non-
agricultural use or
conversion of forest land to non-forest use?


a) Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non‐agricultural use?

Previous Significance Determination: The Initial Study for SEIR No. 339 determined that the Platinum Triangle and its surrounding vicinity are not located within an area desi gnated as Prime Farmland, Farmland of Statewide Importance, Unique Farmland, or Farmland of Local Importance . Because there were no impacts, these resources were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: According to the California Department of Conservation’s Farmland Mapping and Monitoring Program (FMMP) , the Project Site is not located within an area designated Prime Farmland, Farmland of Statewide Importance, or Farmland of Local Importance. The affected segment of Orangewood Avenue and the Santa Ana River reorganization area and all adjoining uses are designated

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Final | March 2022 3-8 Environmental Analysis
“Urban and Built -Up Land.”3 No impact would occur, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

b) Would the project conflict with existing zoning for agricultural use, or a Williamson Act contract?

Previous Significance Determination: The Initial Study for SEIR No. 339 determined that the Platinum Triangle and its surrounding vicinity do not include areas zoned for agricultural use or active Williamson Act contracts. Because there were no impacts, these resources were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: Refer to Impact 3.2 (a) above. Neither the Project Site, nor its adjoining uses are zoned for agricultural use or are under a Williamson Act contract.4 Project implementation would not conflict with existing zoning for agricultural use or a Williamson Act contract, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

c) Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?

Previous Significance Determination: Since the Anaheim City Council certified SEIR No. 339, OPR has revised the CEQA Guidelines Appendix G to include new forestry resources thresholds. Accordingly, this Addendum has conducted the review presented below.

Project‐Specific Analysis: Neither the Project Site, nor its adjoining uses a re zoned as forest land (as defined in PRC section 12220(g), timberland (as defined in PRC Section 4526), or timberland zoned Timberland Production (as defined by Government Code section 4526) by the Anaheim or Orange Zoning Codes. No impacts associated with forest land, timberland, or timberland zoned as Timberland Production would occur, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No increase in significant impacts has resulted.

d) Would the project result in the loss of forest land or conversion of forest land to non‐ forest use?

Previous Significance Determination: Since the Anaheim City Council certified SEIR No. 339, OPR has revised the CEQA Guidelines Appendix G to include new forestry resources thresholds. Accordingly, this Addendum has conducted the review presented below.

3 California Department of Conservation, Farmland Mapping and Monitoring Program, Orange County Important Farmland 2012, January 2015.
4 California Department of Conservation, Agricultural Preserves 2004 (Williamson Act Parcels Orange County, California), 2004.

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Project‐Specific Analysis: Refer to Response 3.2 (c) above. Project implementation would not result in the loss of forest land or conversion of forest land to non-forest use, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No increase in significant impacts has resulted.

e) Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non‐ agricultural use or conversion of forest land to non‐forest use?

Previous Significance Determination: The Initial Study for SEIR No. 339 determined that the Platinum Triangle and its surrounding vicinity do not support agricultural lands. Because there were no impacts, this topic was not further analyzed in SEIR No. 339. Since the Anaheim City Council certified SEIR No. 339, OPR has revised the CEQA Guidelines Appendix G to include new forestry resources thresholds.

Accordingly, this Addendum has conducted the review presented below.

Project‐Specific Analysis: Refer to Responses 3.2 (a) and 3.2 (b) above. Project implementation would not involve changes in the existing environment which would result in conversion of Farmland to non - agricultural use or forestland to non -forest use, and the le vel of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No increase in significant impacts has resulted.

3.2.1 MITIGATION PROGRAM

Since the Anaheim City Council certified SEIR No. 332 and SEIR No. 339, the State of California has revised the CEQA Guidelines Appendix G to address forest and timberland resources. Although SEIR No. 332 and SEIR No. 339 did not evaluate these resources, no such resources are present within the Platinum Triangle and its surrounding vicinity. No impacts would occur and no mitigation is required.

Mitigation Measures from SEIR No. 332

SEIR No. 332 does not include mitigation measures for agricultural and forestry resources.

Mitigation Measures from SEIR No. 339

SEIR No. 339 does not include mitigation measures for agricultural and forestry resources.

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3.3 AIR QUALITY

Where available, the significance criteria established by the applicable air quality management or air pollution
control district may be relied upon to make the following determinations. Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Conflict with or obstruct implementation of the
applicable air quality plan? 
b. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non- attainment under an applicable federal or state ambient air quality standard?

c. Expose sensitive receptors to substantial pollutant
concentrations? 
d. Result in other emissions (such as those leading to odors) adversely affecting a substantial number of
people?


a) Would the project conflict with or obstruct implementation of the applicable air quality plan?

Previous Significance Determination: SEIR No. 339 concluded that although PTMLUP buildout could result in an increase in vehicle miles traveled (VMT) and trips in the local area, the PTMLUP would benefit to the Southern California Association Government (SCAG) region as it would allow for housing opportunities closer to employment centers. SEIR No. 339 determined that the PTMLUP would therefore be consistent with SCAG’s strategies to reduce VMT in the SCAG region and would be consistent with Southern California Air Quality Management District’s 2007 Air Quality Management Plan (2007 AQMP), which was the applicable air quality plan at the time. Impacts concerning conflicting with or obstructing implementation of the SCAQMD’s 2007 AQMP were identified as less than significant, and no mitigation was identified.

Project‐Specific Analysis: The Proposed Project site is located in the South Coast Air Basin (Basin), which is under the jurisdiction of the South Coast Air Quality Management District ( SCAQMD). Pursuant to the Federal Clean Air Act (CAA), the SCAQMD is required to reduce emissions of criteria pollutants for which the Basin is in nonattainment: ozone (O 3), coarse particulate matter (PM 10), and fine particulate matter (PM2.5). These are considered criteria pollutants because they are three of several prevalent air pollutants known to be hazardous to human health.

Since certification of SEIR No. 339, the SCAQMD has adopted the 2016 Air Quality Management Plan (2016 AQMP) to reduce emissions of criteria pollutants for which the Basin is in nonattainment. The 2016 AQMP is a regional and multi-agency effort including the SCAQMD, the California Air Resources Board (CARB), SCAG, and the United States Environmental Protection Agency (EPA) to establish a program of rules and regulations directed at reducing air pollutant emissions and achieving State (California) and Federal air quality standards. The 2016 AQMP pollutant control strategies are based on the latest scientific and technical information and planning assumptions, including SCAG’s 2016 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), updated emission inventory methodologies for various

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source categories, and SCAG’s latest growth forecasts. 5 SCAG’s latest growth forecasts were defined in consultation with local governments and with reference to local general plans. The Project is subject to the SCAQMD’s 2016 AQMP.

The Criteria for determining consistency with the AQMP is defined by the following indicators:

• Consistency Criterion No. 1: The Proposed Project would not result in an increase in the frequency or severity of existing air quality violations, or cause or contribute to new violations, or delay the timely attainment of air quality st andards or the interim emissions reductions specified in the AQMP.
• Consistency Criterion No. 2: The Proposed Project would not exceed the assumptions in the AQMP based on the years of project buildout phase.

Concerning Consistency Criterion No. 1, the Proposed Project would not involve a change of land use which would increase the frequency or severity of existing air quality violations, or cause or contribute to new violations, or delay the timey attainment of air quality standards or the interim emissions reductions specified in the 2016 AQMP. The violations to which Consistency Criterion No. 1 refers are the California ambient air quality standards (CAAQS) and the national ambient air quality standards (NAAQS). The Proposed Project involves the additional widening of the bridge structure over the Santa Ana River, new property acquisition in OCFCD right-of-way, Santa Ana River Trail realignment, drainage facility relocation in the Santa Ana River, a water line extension, and reorganization of municipal jurisdiction of land along the Santa Ana River. Based on the scope and scale of these improvements, Project implementation would not exceed the short-term construction or long-term operational air quality standards beyond what SEIR No. 339 evaluated for the Approved Project. Thus, the Proposed Project would be consistent with Consistency Criterion No. 1, and the level of impact would not increase from that identified in SEIR No. 339.

Concerning Consistency Criterion No. 2, the 2016 AQMP contains air pollutant reduction strategies and demonstrates that the applicable ambient air quality standards can be achieved within the periods required under Federal law. Growth projections from local general plans adopted by cities in the district are provided to SCAG, which develops regional growth forecasts that are used to develop future air quality forecasts for the AQMP. Development consistent with the growth projections in the Anaheim and Orange General Plans is considered consistent with the AQMP.

As discussed, Project implementation would accommodate existing and predicted traffic patterns along Orangewood Avenue. The Proposed Project’s design accommodates additional traffic volumes; proposed improvements would not directly generate new traffic or increase the number of vehicles along the roadway.

The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. The proposed amendments reflect anticipated future development of these areas, which is similar in intensity to what the General Plan already permits . Currently the General Plan designates the subject properties for Mixed Use Urban Core and Ope n Space land use. The proposed

5 SCAQMD is currently working on the next iteration of the AQMP, the 2022 Air Quality Management Plan (2022 AQMP). The 2022 AQMP will incorporate the recently adopted SCAG’s 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (2020-2045 RTP/SCS). However, until the adoption of the 2022 AQMP, project AQMP consistency will be analyzed off the 2016 AQMP and the RTP/SCS that was adopted at the time, the 2016-2040 RTP/SCS.

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amendments for Area 1 and 1A would spread the intensities permitted General Plan Mixed -Use Urban Core land use designation over a slightly larger area; however, the amendments would not increase the maximum intensities permitted by the General Plan for the Platinum Triangle. The proposed amendments for Area 2 would change the land use designation for Open Space to Parks; the General Plan permits both uses at the same maximum FAR of 0.10. Any future park project would be subject to CEQA. There would be no change in the General Plan designations for the remainder of the area subject to the reorganization.

Given that the permitted type and intensity of development would be similar to what was previously - analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

As a roadway improvement and annexation project, Project implementation would not conflict with the population and employment growth assumptions identified in the 2016 AQMP. For these reasons, the Project would be consistent with Consistency Criterion No. 2, and Project implementation would not conflict with or obstruct implementation of the 2016 AQMP.

Significance Determination: No substantial increase in the level of impact from previous analysis.

b) Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non‐attainment under an applicable Federal or State ambient air quality standard?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 pages 5.2 -17 to

5.2-19.

Pre
vious Significance Determination: SEIR No. 339 concluded that PTMLUP implementation had the potential to result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attain
ment un der applicable Federal or State ambient air quality standards.

Despite incorporation of SEIR No. 339 MM 2 -1 through MM 2 -6, SEIR No. 339 found that construction and operation would generate short -te
rm and long-te
rm air pollutants that would exceed SCAQMD’s
regional significance thresholds. A significant and unavoidable impact was identified, and a Statement of Overriding Considerations was adopted by the City Council at SEIR No. 339 certification.

Project‐Specific Analysis:

Sh
ort-Te
rm Construction

Du
st (PM10) is typically a major concern during rough grading activities. Because such emissions are not amenable to collection and discharge through a controlled source, they are called “fugitive emissions.” Fugitive dust emission rates vary as a function of many parameters (e.g., soil silt, soil moisture, wind speed, area disturbed, number of vehicles, depth of disturbance or excavation). All development projects in the Cities of Anaheim and Orange, including the Proposed Project, are subject to SCAQMD rules and regulations to reduce fugitive dust emissions.

Pr
oject construction would be subject to compliance with the City of Orange Grading Ordinance (Orange Municipal Code Chapter 16.40, Grading Requirements), which incorporates by reference the City of Orange Manual of Grading. The City of Orange Grading Ordinance establishes minimum requirements to regulate excavation, grading, and earthwork construction, which act to reduce impacts concerning fugitive

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dust. In addition to City requirements, all grading operations, land clearing, loading, stockpiling, landscaping, vehicular track-out, and haul routes would be subject to compliance with SCAQMD Rule 403, which is included in SEIR No. 339 as MM 2-2. SC
AQMD Rule 403 (Fugitive Dust) requires fugitive dust
sources to implement best available control measures for all sources, and all forms of visible particulate matter are prohibited from crossing any property line. SCAQMD adopted Rule 403 to reduce PM emissions from any transportation, handling, construction, or st orage activity that has the potential to generate fugitive dust. MM 2-2 of SEIR No. 339 includes these PM suppression techniques.

In
addition to the City of Orange Grading Ordinance and SEIR No. 339 MM 2-2 (SCAQMD Rule 403), Project construction would be subject to SCAQMD Rule 1113 (Architectural Coatings); Rule 431.2 (Low Sulfur Fuel); and Rule 1186/1186.1 (Street Sweepers), among others. Project construction would also demonstrate conformance with SEIR No. 339 MM 2 -1 and 2-3 to reduce construction-related emissions.

Based on the scope and scale of the Project’s proposed improvements, Project implementation would not exceed the short-term construction air quality standards beyond what SEIR No. 339 concluded, following compliance with the City of Orange Grading Ordinance and relevant SCAQMD Rules. Thus, the Project’s construction-generated criteria pollutant emissions would not exceed their respective thresholds and the level of impact would not increase from that identified in SEIR No. 339.

Lon
g-Ter
m Operations

The Project does not include components which would generate permanent stationary (i.e., new buildings) or new mobile sources of emissions. Therefore, by its nature, the Project would not generate quantifiable criteria emissions from long -term operations. The proposed roadway widening would accommodate existing and predicted traffic demands in compliance with SEIR No. 339 MM 2-5 and would not directly generate new traffic or increase the numbers of vehicles along the roadway. The Project’s pedestrian sidewalks and bicycle lanes would improve non -motorized transportation options. As discussed in Section 3.16, Transportation and Traffic, Project implementation would not impact existing traffic conditions along Orangewood Avenue.

The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. The proposed amendments would result in land use that i s similar in intensity to what the General Plan currently permits. Currently the General Plan designates the subject properties for Mixed-Use Urban Core and Open Space land use. The proposed amendments for Area 1 and 1A would spread the intensities permitted General Plan Mixed-Use Urban Core land use designation over a slightly larger area; however, the amendments would not increase the maximum intensities permitted by the General Plan for the Platinum Triangle. The proposed amendments for Area 2 would change the land use designation for Open Space to Parks; the General Plan permits both uses at the same maximum FAR of

0.10. There would be no change in the General Plan designations for the remainder of the area subject to the reorganization. Any future development of any of these sites would be subject to CEQA and analyzed on a per project basis for short-term construction and long-term operational air quality impacts. Given that the permitted type and intensity of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

Thus, the Project would not result in permanent stationary or mobile sources of emissions and the level of impact would not increase from that identified in SEIR No. 339.

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Cumulative Impacts

Cumulatively considerable projects could contribute to an existing or projected air quality exceedance since the SCAB is currently in nonattainment for O
3 and PM2.5. The improvements identified in S ection

2.0 are not expected to substantially increase the PTMLUP’s short -term and long- term air pollutants identified in SEIR No. 339. All cumulative development occurring within the Basin would be subject to compliance with applicable SCAQMD rules and regulations. As the Project would not involve substantial changes which would contribute a cumulatively considerable net increase in the region for any non -
att
ainment criteria pollutant beyond that identified in SEIR No. 339 , the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

c) Would the project expose sensitive receptors to substantial pollutant concentrations?

Previous Significance Determination: Sensitive populations (sensitive receptors) are more susceptible to air pollution effects than the general population. Sensitive populations that are in proximity to localized sources of toxics and CO are of particular concern. Some land uses are considered more sensitive to air quality changes than others, depending on the population groups and the activities involved. CARB identifies the following types of people as most likely to be adversely affe cted by air pollution: children under 14; elderly over 65; athletes; and, people with cardiovascular and chronic respiratory diseases. Locations with potential to contain a high concentration of these sensitive population groups are called sensitive receptors and include residential areas, hospitals, day -care facilities, elder-care facilities, places of worship, elementary schools, and parks.

SE
IR No. 339 concluded that PTMLUP implementation could expose sensitive receptors to substantial pollutant concentrations. Despite implementation of MM 2-1 through 2-9, SEIR No. 339 found that: (1) construction activities would potentially expose sensitive receptors to substantial pollutant concentrations of NOx, CO, PM10, and PM2.5; and (2) sensitive land uses within 500 feet of SR-57 an d I-5 , or within the recommended buffer distances to facilities emitting TACs , may be exposed to substantial pollutant concentrations. I mpacts were determined to remain significant and unavoidable, and a Statement of Overriding considerations was adopted by the City Council when SEIR No. 339 was certified.

Project‐Specific Analysis: Sensitive receptors within 500 feet of the Project area include a surgical center (Orangewood Surgical Center) and residential uses to the north and south of the Project Site, respectfully.

The Proposed Project involves the additional widening of the bridge structure over the Santa Ana River, new property acquisition in OCFCD right -of-way, Santa Ana River Trail realignment, drainage facility relocation in the Santa Ana River, a water line extension, and annexation of land along the Santa Ana River. Construction activities would involve incidental amounts of toxic substances such as oils, solvents, paints, adhesives, and coatings. The use and application of these substances would comply with all applicable SCAQMD rules for their use, storage, and disposal. The SCAQMD has established that impacts to air quality are significant if there is a potential to contribute or cause localized exceedances of the Federal and/or State ambient air quality standards (NAAQS/CAAQS). Collectively, these are referred to as localized significance thresholds (LSTs). Based o n the scope and scale of these improvements, it is not anticipated that Project construction would involve LST construction impacts greater than those identified in SEIR No. 339. In accordance with SEIR No. 339 MM 2 -2, Project construction would also demonstrate compliance with SCAQMD Rule 403 to reduce impacts to nearby sensitive receptors. In addition, the

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Project would demonstrate compliance with SEIR No. 339 MM 2 -1 and MM 2 -3 to reduce onsite and export-related construction emissions. Compliance with SEIR No. 339 MM 2-1 through 2-3 wo uld reduce
LST construction impacts to a less than significant level.

Th
e proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. The proposed amendments would result in land use that is similar in intensity to what the General Plan currently permits. Currently the General Plan designates the subject properties for Mixed-Use Urban Core and Open Space land use. The proposed amendments for Area 1 and 1A would spread the intensities permitted General Plan Mixed-Use Urban Core land use designation over a slightly larger area; however, the amendments would not increase the maximum intensities permitted by the General Plan for the Platinum Triangle. The proposed amendments for Area 2 would change the land use designation for Open Space to Parks; the General Plan permits both uses at the same maximum FAR of

0.10. There would be no change in the General Plan designations for the remainder of the area subject to the reorganization. Any future development of any of these sites would be subject to CEQA. Given that the permitted type and intensity of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

Therefore, sensitive receptors would not be subject to a significant air quality impact during construction and level of impact would not increase from that identified in SEIR No. 339.

Carbon Monoxide Hotspots

CO emissions are a function of vehicle idling time, meteorological conditions, and traffic flow. Under certain extreme meteorological conditions, CO concentrations near a congested roadway or intersection may reach unhealthful levels (i.e., adversely affecting residents, schoolchildren, hospital patients, the elderly, etc.). The SCAQMD requires a quantified assessment of CO hotspots when a Project increases the volume-to-capacity ratio (also called the intersection capacity utilization [ICU]) by 0.02 (two percent) for any intersection with an existing level of service LOS D or worse. Because traffic congestion is highest at intersections, where vehicles queue and are subject to reduced speeds, these hot spots are typic ally produced at intersections.

The Project involves widening Orangewood Avenue and related improvements and would not generate new vehicle trips beyond those identified in SEIR No. 339; refer to Section 3.17. In compliance with SEIR No. 339 MM 2 -5, Project implementation would reduce congestion and improve traffic flow along Orangewood Avenue. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. The proposed amendments would result in land use that is similar in intensity to what the General Plan currently permits. Currently the General Plan designates the subject properties for Mixed -Use Urban Core and Open Space land use. The proposed amendments for Area 1 and 1A would spread the intensities permitted General Plan Mixed-Use Urban Core land use designation over a slightly larger area; however, the amendments would not increase the maximum intensities permitted by the General Plan for the Platinum Triangle. The proposed amendments for Area 2 would change the land use designation for Open Space to Parks; the General Plan permits both uses at the same maximum FAR of 0.10. There would be no change in the General Plan designations for the remainder of the area subject to the reorganization. Any future development of any of these sites would be subject to CEQA and analyzed on a per project basis for short -term construction and long-term operational air quality impacts. Given that the permitted type and intensity of development would be similar to what was

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previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. Thus, the Proposed Project would not increase the ICU or nearby intersections to warrant a CO hotspot analysis. Impacts would be less than significant and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

d) Would the project result in other emissions (such as those leading to odors ) adversely affecting a substantial number of people?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 on page 5.2-27.

Pr
evious Significance Determination: SEIR No. 339 concluded that PTMLUP buildout would involve less than significant impacts concerning objectionable odors with the incorporation of SEIR No. 339 MM 2-1

0. MM 2-10 ap
plies to projects located within 1,000 feet of an industrial facility that emits substantial odors (e.g., wastewater treatment plants, food processing facilities, coffee roasters).

Project‐Specific Analysis: Land uses generally associated with odor complaints include agricultural uses (livestock and farming), wastewater treatment plants, food processing plants, chemical plants, composting operations, refineries, landfills, dairies, and fiberglass molding facilities. The Project involves roadway improvements and does not contain land uses typically associated with emitting objectionable odors. Potential odor sources associated with Project implementation may result from construction equipment exhaust and the application of asphalt during construction activities . H owever, standard construction requirements would minimize odor impacts from construction. Construction odor emissions would be intermittent i n nature over a temporary period, would disperse rapidly, would not affect a substantial number of people, and would cease upon completion of the respective phase of construction. Additionally, construction activities would be required to comply with SCAQ MD Rule 402 to prevent occurrences of public nuisances. As a roadway infrastructure and annexation project, Project implementation would not create objectionable odors and MM 2-10 is not required.

The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. The proposed amendments would result in land use that is similar in intensity to what the General Plan currently permits. Currently the General Plan designates the subject properties for Mixed-Use Urban Core and Open Space land use. The proposed amendments for Area 1 and 1A would spread the intensities permitted General Plan Mixed-Use Urban Core land use designation over a slightly larger area; however, the amendments would not increase the maximum intensities permitted by the General Plan for the Platinum Triangle. The proposed amendments for Area 2 would change the land use designation for Open Space to Parks; the General Plan permits both uses at the same maximum FAR of

0.10. There would be no change in the General Plan designations for the remainder of the area subject to the reorganization. Any future development of any of these sites would be sub ject to CEQA and analyzed on a per project basis. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

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For the above reasons, the Project’s potential construction -related and operational odor impacts are considered less than significant, and the level of impact would not increase from th at identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

3.3.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

Refer to the Mitigation Measures from SEIR No. 339 below, which are based on adopted Mitigation Measures from SEIR No. 332.

Mitigation Measures from SEIR No. 339

SEIR No. 339 includes measures to reduce potential impacts associated development and infrastructure improvements within the Platinum Triangle. The following measures from SEIR No. 339 are applicable to the Proposed Project.
6 Any modifications to the original measures are shown in strikethrough for deleted text and new, inserted text is underlined.

MM 2-1 O ngoing during grading and construction, the property owner/developer City shall be responsible for requiring contractors to implement th e following measures to reduce construction-rel
ated emissions; however, the resultant value is expected to remain significant.

a. The contractor shall ensure that all construction equipment is being properly serviced and maintained in accordance with the manufacturer’s recommendations to reduce operational emissions.

b. Th
e co ntractor shall use Tier 3 or higher, as identified by the U nited Sta tes Environmental Protection Agency, off-ro
ad construction equipment with higher air
pollutant emissions standards for equipment greater than 50 horsepower, based on manufacturer’s availability.

c. Th
e contractor shall utilize existing power sources (e.g., power poles) or clean-fu el
generators rather than temporary diesel-po
wer generators, where feasible.

MM 2-2 O ngoing during grading and construction, the property owner/developer City shall implement the following measures in addition to the existing requirements for fugitive dust control under South Coast Air Quality Ma nagement District Rule 403 to fu rther reduce PM 10 and PM 2.5 emissions. To assure compliance, the City shall verify compliance that these measures have been implemented during normal construction site inspections. The measures to be implemented are listed below:

a. During all grading activities, the pr operty owner/developer City’s const ruction contractor shall re-es tablish ground cover on the co nstruction site through seeding

6 Mitigation measure numbering corresponds to Platinum Triangle Master Land Use Plan Appendix C, Updated and Modified Mitigation Monitoring Program Number 106C.

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and watering as quickly as possible to achieve a minimum control efficiency for PM10 of 5 percent.

b. During all grading activities, the pr operty owner/developer City’s const ruction contractor shall apply chemical soil stabilizers to o n-si te haul roads to achieve a control efficiency for PM10 of 85 percent compared to travel on unpaved, untreated roads.

c. The property owner/developer City’s construction contractor shall phase grading to prevent the susceptibility of large areas to erosion over extended periods of time.

d. The property owner/developer City’s construction contractor shall schedule activities to minimize the amount of exposed excavated soil during and after the end of work periods.

e. During all construction activities, the property owner/developer City’s construction contractor shall sweep streets with Rule 1186-co mpliant PM10-efficient v acuum units on a daily basis if silt is carried over to adjacent public thoroughfares or occurs as a result of hauling.

f. During active de molition and d ebris removal and grad ing, the property owner/developer City’s construction contractor shall suspend demolition and grading operations w hen wind speeds exceed 25 miles per hour to ach ieve an emissions control efficiency for PM10 under worst-ca se wind conditions of 98 percent.

g. During all construction activities, the property owner/developer City’s construction contractor shall maintain a minimum 12-in ch freeboard ratio on haul trucks hauling dirt, sand, soil, or other loose materials and tarp materials with a fabric cover or other suitable means to achieve a control efficiency for PM10 of 91 percent.

h. During all construction activities, the property owner/developer City’s construction contractor shall water exposed ground surfaces and disturbed areas a minimum of every three hours on the construction site to achieve an emissions reduction control efficiency for PM10 of 61 percent.

i. During active demolition and debris removal, the property owner/developer City’s construction contractor shall apply water to disturbed soils at the end of each day to achieve an emission control efficiency for PM10 of 10 percent.

j. During scraper unloadi ng a nd loading, th e property owner/developer City’s construction contractor shall ensure that a ctively disturbed areas maintain a minimum soil moisture content of 12 percent by use of a moveable sprinkler system or water truck to achieve a control efficiency for PM10 of 69 percent.

k. During all construction activities, the property owner/developer City’s construction contractor shall limit on-si te vehicle speeds on un paved roads to no more than 15 miles per hour to achieve a control efficiency for PM10 of 57 percent.

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MM 2-3 P rior to approval of each grading plan (for Import/Export Plan) a nd prior to is suance of demolition permits (for Demolition P lans), the property owner/developer City shall submit Demolition and Import/Export Plans detailing construction and demolition (C&D) recycling and waste reduction measures to be i mplemented to recover C&D materials. These plans shall i nclude i dentification of off-s ite locations for m aterials e xport from the project a nd options for disposal of excess material. These options may include recycling of materials on- sit
e or to an adjacent site, sale to a soil broker or contractor, sale to a project in the vicinity or tr ansport to an environmentally cleared landfill, with attempts made to move it within Orange County. The property owner/developer City s hall offer recyclable building materials, such as asphalt or concrete for sale or removal by private firms or public agencies for use in construction of other projects if not all can be reused at the project siteProject Site.

MM 2-5 In accordance with the ti ming required by the Traffic and Transportation Ma nager during the Plans, Specifications, and Estimate phase, but no later than prior to the first final Building and Zoning inspec tion, the City property owner/developer shall implement the following measures to reduce long-term o perational CO, NOX, ROG, and PM10 emissions: (5.2-5 )

• Traffic lane i mprovements and signal ization as outlined in the Revised Platinum Triangle Expansion Project Traffic Study Report by Parsons Brinkerhoff, August 2010, and Master Plan of Arterial Highways (MPAH) shall be implemented as required by the Traffic and Transportation Manager.

• The property owner/developer City shall place bus be nches and/or shelters as required by the Traffic a nd Transportation Manager at locations along any site frontage routes as needed.

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3.4 BIOLOGICAL RESOURCES

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U .S. Fish and Wildlife Service?

b. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the
California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?

c. Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?

d. Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with
established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery sites?

e. Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?

f. Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state habitat conservation plan?


This section is primarily based on the Results of a Biological Resources Assessment for the Orangewood Avenue Bridge Widening Over Santa Ana River in the City of Orange, California (Biological Resources Assessment) and Jurisdictional Delineation for the Orangewood Avenue Bridge Widening Over Santa Ana River in the City of Orange, California (Jurisdictional Delineation) prepared by Michael Baker International, dated September 28, 2017 and January 22, 2018, respectively; refer to Appendix A, Biological Resources Assessment, and Appendix B, Jurisdictional Delineation.

a) Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?

Previous Significance Determination: The Ini tial Study for SEIR No. 339 concluded that no native biological resources exist within the Platinum Triangle due to the site’s developed and disturbed nature.

The Initial Study found that buildout of the PTMLUP would not impact candidate, sensitive, or special - sta
tus species and no mitigation was necessary. Because there were no impacts, these resources were not further analyzed in SEIR No. 339.

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Project‐Specific Analysis: A Biological Resources Assessment was prepared for th e Proposed Project and included a habitat assessment to survey existing biological conditions on and surrounding the Project Site. In addition to the habitat assessment, the California Natural Diversity Database (CNDDB) was queried for reported locations of listed and special- status plant and wildlife species as well as special-status vegetation communities near the Project Site; refer to Appendix A. A search of published records of these species was conducted within this quadrangle using the CNDDB Rarefind5 online software. The California Native Plant Society (CNPS) Inventory of Rare and Endangered Plants supplied information regarding the distribution and habitats of plants in the Project vicinity. The habitat assessment evaluated the ability of the plant communities found on- site to provide suitable habitat for relevant special-status plant and wildlife species.

Special-Status Plant Species . No special -status plant species were observed on -site during the habitat assessment. Based on the records search, a total of four special-status plant species have been recorded within the vicinity of the Project by the CNDDB and CNPS Online Inventory. However, most of these species have a low potential or are not expected to occur on -site due to a lack of suitable habitat to support them. No impact would occur in this regard.

Special-Status Wildlife Species. No special-status wildlife species were observed on -site during the habitat assessment. Based on the records search, a total of 18 special-status wildlife species have been recorded within the vicinity of the Project by the CNDDB. However, most of these species have a low potential or are not expected to occur on-site due to a lack of suitable habitat to support them. No impact would occur in this regard.

Special-Status Plant Communities . No special-status plant communities were observed on -site during the habitat assessment. Based on the results of the habitat assessment, no special -status plan communities occur within the Project area. No impact would occur in this regard.

U.S. Fish and Wildlife Service (USFWS) Critical Habitat . No critical habitat has been mapped by the USFWS within or adjacent to the Project Site. Since the Proposed Project would not result in the loss or adverse modification to Critical Habitat, consultation with the USFWS under Section 7 of the Federal Endangered Species Act (FESA) would not be required and no impact would occur in this regard.

Significance Determination: No substantial increase in the level of impact from previous analysis.

b) Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the Platinum Triangle does not contain riparian habitat or other sensitive natural communities; thus, PTMLUP buildout would not impact riparian habitat or other sensitive natural communities and no mitigation was necessary. Because there were no impacts, these resources were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: A Jurisdictional Delineation was prepared for the Proposed Project and included a site visit to delineate U.S. Army Corps of Engineers (Corps), Santa Ana Regional Water Quality Control Board (Santa Ana RWQCB), and California Department of Fish and Wildlife’s (CDFW) jurisdictional authority located within the Project Site; refer to Appendix B. Based on the Jurisdictional Delineation, the Proposed Project would result in 0.03-acre of permanent impacts and 1.12 acres of temporary impacts to

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CDFW un-vegetated streambed. As a result, Project implementation would require the following State and Federal permits : Corps Section 408 Permit and Section 404 Nationwide Permit 14 Linear Transportation Projects, Regional Board Section 401 Water Quality Certific ation, and CDFW 1602 Streambed Alteration Agreement. Following approval of the required State and Federal permits , no impacts to riparian habitat or other sensitive natural communities would occur, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

c) Would the project have a substantial adverse effect on State or Federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 Appendix A, Notice of Preparation and Initial Study.

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the Platinum Triangle does not contain wetlands; thus, PTMLUP buildout would not impact federally protect wetlands and no mitigation was necessary. Because there were no impacts, these resources were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: No substantial change from previous analysis. According to the Jurisdictional Delineation, the Project Site does not support wetland features ; refer to Appendix B. Therefore, no impacts associated with federally protected wetlands would occur, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

d) Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded t hat the Platinum Triangle does not contain areas associated with wildlife corridors or nursery sites; thus, PTMLUP buildout would not impact migratory wildlife corridors and native wildlife nursery sites and no mitigation was necessary. Because there were no impacts, these resources were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: No substantial change from previous analysis. Due to the highly disturbed nature of the Project Site and surrounding areas, the Project Site does not currently function as a migratory corridor or linkage. In addition, the Santa Ana River is sand-bottomed, regularly maintained, and devoid of vegetation communities and does not function as a migratory corridor or linkage. The extensive amount of existing urban development along with the existing roadways, including Orangewood Avenue, Gene Autry Way , and State College Boulevard, creates a highly fragmented, noncontiguous landscape that is not conducive to substantial wildlife movement. Therefore, no impacts associated with wildlife movement corridors or nursery sites would occur, and the level of impact would not increase from those levels identified in SEIR No. 339.

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Significance Determination: No substantial increase in the level of impact from previous analysis.

e) Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the Platinum Triangle area was not subject to a tree preservation ordinance or other local regulation protecting biological resources; thus, PTMLUP buildout would not conflict with local policies or ordinances protecting biological resources and no mitigation was necessary. Because there were no impacts, this topic not further analyzed in SEIR No. 339.

Project‐Specific Analysis: Pursuant to Anaheim Municipal Code Chapter 11.12, Designation of Landmark Trees, the Anaheim City Council has the authority to designate any tree on public property as a landmark tree. Anaheim Municipal Code Section 13.12.080, Interference with Street Trees – Permission Required, states that no person shall remove a street tree without the written permission of the Anaheim Director of Community Services. Similarly, Orange Municipal Code Section 12.28.020, Permit – Required for Removal or Planting, states that no person shall plant or remove any tree or shrub within public street or right-of-way without having first obtained a permit from the City.

At the time of this writing, the Proposed Project does not include any tree removal activities. Further, no trees in the Project vicinity are designated as landmark trees as defined in Anaheim Municipal Code Chapter 11.12. A ny tree removal , if deemed necessary, would occur in conformance with Anaheim Municipal Code Section 13.12.080 and Orange Municipal Code Section 12.28.020. Thus, the Proposed Project would not conflict with any local policies or ordinances protecting biological resources. Therefore, conformance with City requirements would ensure no impacts associated with local policies or ordinances would occur, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

f) Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the Platinum Triangle is not affected by a habitat conservation plan (HCP), natural community conservation plan (NCCP), or other adopted local, regional, or S tate habitat conservation plant; thus, PTMLUP buildout would not conflict with the provisions of an adopted HCP , NCCP, or other approved local, regional, or State habitat conservation plan and no mitigation was necessary. Because there were no impacts, these resources were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: According to the County of Orang e (Central/Coastal) NCCP/HCP , the Platinum Triangle is not affected by the NCCP/HCP conservation plan area. Thus, Project implementation would not conflict with the provisions of an adopted HCP, NCCP, or other adopted local, regional, or State habitat conservation plan, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

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3.4.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

SEIR No. 332 does not include mitigation measures for biological resources.

Mitigation Measures from SEIR No. 339

SEIR No. 339 does not include mitigation measures biological resources.

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3.5 CULTURAL RESOURCES

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines
Section 15064.5?

b. Cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA
Guidelines Section 15064.5?

d. Disturb any human remains, including those interred
outside of dedicated cemeteries? 

a) Would the project cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 in Appendix A, Notice of Preparation and Initial Study.

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the Platinum Triangle does not contain any historical resources as defined by CEQA Guidelines Section 15064.5. The Platinum Triangle is not located within the Anaheim Colony Historic District and none of the structures within the PTMLUP area were identified on the Qualified Historic Structures list of the Anaheim Colony Historic District Preservation Plan. No known historic archaeological sites within the PTMLUP were identified. The Initial Study concluded that no impacts would occur and no mitigation was necessary.

Because there were no impacts, these resources were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: Historic resources generally consist of buildings, structures, improvements, and remnants associated with a significant historic event or person(s) and/or having a historically significant s tyle, design, or achievement. Damage to or demolition of such resources is typically a significant impact. Impacts to historic resources can occur through direct impacts, such as destruction or removal, and through indirect impacts, such as a change in t he setting of a historic resource. According to SEIR No. 339 Addendum No. 7, 13 National Register of Historic Places -listed properties are located within the City of Anaheim. According to Orange G eneral Plan EIR Figure 5.5 -1 ( Designated Historic Resources), 11 NRHP-designated resources are located within the City of Orange.

The Project Site encompasses an approximately half-mile long segment of Orangewood Avenue and the Santa Ana River reorganizational area. Based on SEIR No. 339 Addendum No. 7 and Orange General Plan EIR Figure 5.5 -1, no known historic resources are located within or directly adjacent to the Proposed Project. Thus, Project implementation would not cause a substantial adverse change in the significance of a historical resource as defined in Section 15064, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

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b) Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the PTMLUP area does not contain any known archaeological resources since the Platinum Triangle area has already been disturbed and the potential for subsurface resource is remote . There are no known prehistoric/historic archaeological sites located within the PTMLUP area. No impact to pre -hi storic or
historic archaeological resources were identified and no mitigation was required. Because there were no impacts, these resources were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: Archaeological sites are locations that contain resources associated with former human activities and may contain such resources as human skeletal remains, waste from tool manufacture, tool concentrations, and/or discoloration or accumulation of soil or food remains. As concluded in SEIR No. 339 and its subsequent addendums, no pre -historic or historic archaeological resources have been identified in the PTMLUP area. The Project would occur along a fully -improved segment of Orangewood Avenue surrounded by developed uses . In addition, the Project’s proposed Santa Ana River Trail improvements would occur within a heavily disturbed segment of the River that has been subject to channelization and frequent human use. Thus, Project-related ground disturbing activities would have a remote potential to uncover previously-unknown buried resources. Further, the proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development would be subject to CEQA and analyzed on a per project basis. Given that the permitted type and intensity of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

Nonetheless, in compliance with 14 CCR Section 15064.5, if Project construction results in the inadvertent discovery of subsurface archaeological resources, all construction activities within 100 feet of the find would immediately halt until a qualified archaeologist that meets the Secretary of the Interior’s Professional Qualification Standards for Archaeology evaluates the significance of the find and determines whether additional study is warranted. Depending on the significance of the find, the archaeologist may simply record the find and allow work to continue. If the discovery proves significant under CEQA, additional work, such as preparation of an archaeological treatment plan, testing, or data recovery, may be warranted. Compliance with existing State regulatory requirements would ensure impacts concerning archaeological resources are less than significant, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

c) Would the project disturb any human remains, including those interred outside of formal cemeteries?

Previous Significance Determination: The Initial Study for SEIR No. 339 determined that the Platinum Triangle does not contain human remains, including those outside of formal cemeteries since the PTMLUP area has already been disturbed and the potential for any subsurface cultural resources is remote. The Initial Study for SEIR No. 339 determined that the PTMLUP would have no impact to human remains and no mitigation was necessary. Because there were no impacts, these resources were not further analyzed in SEIR No. 339.

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Project‐Specific Analysis: Consistent with the findings of the Initial Study for SEIR No. 339, i t is not anticipated that human remains or informal cemetery areas are present on the Project Site; however, all ground-disturbing activities, such a s grading or excavation have the potential to inadvertently disturb human remains. If human remains are found, those remains would require proper treatment in accordance with applicable laws. PRC Section 5097.98 and Health and Safety Code Sections 7050.5–7055 describe the general provisions regarding human remains, including the requirements if any human remains are accidentally discovered during Project construction.

As required by State law, procedures set forth in PRC Section 5097.98 would be implemented, including notification of the County Coroner, notification of the Native American Heritage Commission, and consultation with the individual identified by the Native American Heritage Commission to be the “most likely descendant.” Compliance wi th existing State regulations, which detail the appropriate actions necessary in the unlikely event that human remains are uncovered, would ensure that Project implementation does not impact human remains, and the level of impact would not increase from th at identified in SEIR No. 339.

3.5.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

SEIR No. 332 does not include mitigation measures for cultural resources.

Mitigation Measures from SEIR No. 339

SEIR No. 339 does not include mitigation measures for cultural resources.

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3.6 ENERGY

The previously certified SEIR No. 339 did not evaluate energy as it was not required in the CEQA Guidelines at the time SEIR No. 339 was prepared.

On October 26, 2010, the City of Anaheim certified the SEIR No. 339 that analyzed the potential impacts associated with development of the revised Platinum Triangle Expansion Project. Although this previous environmental document did not include an energy analysis, a supplemental environmental analysis of energy impacts cannot be required absent new information on that front. The implementation of project design features and mitigation measures related to energy efficiency have typically been incorporated into a project’s air quality analysis. Additionally, Public Resources Code Section 21100(b)(3) and CEQA Guidelines Section 15126.4 require EIRs to describe, where relevant, the wasteful, inefficient, and unnecessary consumption of energy caused by a project. Thus, the effect of energy usage could have been raised in 2010 when the City considered the EIR. A challenge to an EIR must be brought within 30 days of the lead agency’s notice of approval. (Pub. Resources Code, § 21167[b].) Under Public Resources Code Section 21166(c), an agency may not require a supplemental environmental review unless new information, which was not known and could not have been known at the time the EIR was approved, becomes available. After a project has been subjected to environmental review, the statutory presumption flips in favor of the project proponent and against further review. (Moss v. County of Humboldt [2008] 162 Cal.App.4th 1041, 1049-1050.) “‘[S]ection 21166 comes into play precisely because in-depth review has already occurred [and] the time for challenging the sufficiency of the original EIR has long since expired.’” (Id., 1050.) There is no competent evidence of new information of severe impact, and thus the City may rely on an addendum. Accordingly, the City finds t hat energy is not “new information” under Public Resources Code Section 21166.

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during project construction or
operation?

b. Conflict with or obstruct a State or local plan for
renewable energy or energy efficiency? 

a) Would the project result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation?

Previous Significance Determination: As detailed in SEIR No. 339, Project implementation would be required to comply with mandated energy efficiency programs and regulations the California Building Energy Efficiency Standards (Title 24) of the California Building Code (CBC) . Future development of structures would be required to submit energy calculations that demonstrate each new structure exceeds Title 24 standards by 10 percent (SEIR No. 339 Mitigation Measure 2 -6 and SEIR No. 332 Mitigation

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Measure 10-21) and would be subject to several specified Title 24 energy saving practices (SEIR No. 332 Mitigation Measure 10-22).

Project‐Specific Analysis: The Project would not result in an increase in construction -related or operational energy demand beyond that anticipated for the Revised Platinum Triangle Expansion Project.

As a roadway widening and annexation project, the Project does not propose habitable structures and is limited to widening an existing segment of Orangewood Avenue and associated utility infrastructure improvements. These types of improvements would not have the potential to result in a significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during Project operation. SEIR No. 339 Mitigation Measure 2-6 and SEIR No. 332 Mitigation Measures 10- 21 and 10-22 would not apply to the Proposed Project in this regard. Project lighting would be similar to existing lighting sources along Orangewood Avenue and would be subject to the applicable energy efficiency programs and regulations detailed above. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development would be subject to CEQA and analyzed on a per project basis. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. Thus, the Proposed Project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during Project construction or operation and a less than significant impact would occur. As noted above, the City has determined that energy does not constitute new significant information under Public Resources Code Section 21166.

Significance Determination: No increase in significant impacts has resulted.

b) Would the project conflict with or obstruct a State or local plan for renewable energy or energy efficiency?

Previous Significance Determination: SEIR No. 339 determined that the Project would be required to comply with the California Building Energy Efficiency Standards of the CBC . In addition, mitigation measures were included in ensure structural development exceeds Title 24 standards by 10 percent and is subject to Title 24 energy sa ving practices (SEIR No. 339 Mitigation Measure 2 -6 and SEIR No. 332 Mitigation Measures 10-21 and 10-22).

Project‐Specific Analysis: As discussed, the Project would be required to comply with all applicable energy efficiency programs and regulations . Impacts in this regard would be less than significant. As a roadway improvement and annexation project, the Project would not be subject to SEIR No. 339 Mitigation Measure 2-6 and SEIR No. 332 Mitigation Measures 10-21 and 10-22. As noted above, the City has determined that energy does not constitute new information under Public Resources Code Section 21166.

Significance Determination: No increase in significant impacts has resulted.

3.6.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

SEIR No. 332 mitigation measures are not applicable to the Proposed Project.

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Mitigation Measures from SEIR No. 339

SEIR No. 339 mitigation measures are not applicable to the Proposed Project.

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3.7 GEOLOGY AND SOILS

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death
involving:

1) Rupture of a known earthquake fault, as delineated
on the most recent Alquist-Priolo Earthquake Fault
Zoning Map issued by the State Geologist for the
area or based on other substantial evidence of a
known fault? Refer to Division of Mines and
Geology Special Publication 42.

2) Strong seismic ground shaking? 
3) Seismic-related ground failure, including
liquefaction? 
4) Landslides? 
b. Result in substantial soil erosion or the loss of topsoil?  c. Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project,
and potentially result in on- or off -site landslide, lateral spreading, subsidence, liquefaction or collapse?

d. Be located on expansive soil, as defined in Table 18 -1- B of the Uniform Building Code (1994), creating
substantial direct or indirect risks to life or property? 
e. Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal
systems where sewers are not available for the disposal of waste water?

f. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? 

a) Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 Appendix A.

i) Rupture of a known earthquake fault, as delineated on the most recent Alquist ‐Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the PTMLUP area is not underlain by Alquist-Pr
iolo Earthquake Fault Zone; thus, PLMLUP buildout would not involve impacts associated with earthquake fault rupture and no mitigation was necessary. Because there were no impacts, these impacts were not further analyzed in SEIR No. 339.

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Project‐Specific Analysis: The Project Site, like the rest of Southern California, is situated within a seismically active region as the result of being located near the active margin between the North American and Pacific tectonic plates. However, the Project Site is not located within an Alquist -Prio lo Earthquake
Fault Zone.7 Further, no known or potentially active faults traverse the Project Site. As indicated in SEIR No. 339 Addendum No. 7, the El Modeno and Peralta Hill faults are the closest active faults to the Project Site, which are located approximately three miles to the northeast.

As a roadway widening project, the Proposed Project does not propose habitable structures and is limited to widening an existing segment of Orangewood Avenue and associated utility infrastru cture improvements. These types of improvements are not particularly at-risk to earthquake-induced damage; thus, Project implementation would not increase the risk of loss, injury, or death associated with fault rupture. The proposed amendments to the Ge neral Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development would be subject to CEQA and analyzed on a per proje ct basis. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. Therefore, no impacts associated with fault rupture would result, and the level of impact from the Proposed Project would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

ii) Strong seismic ground shaking?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the PTMLUP area may be exposed to impacts from earthquakes, including strong seismic ground shaking; thus, impacts associated with strong seismic ground shaking would be less than significant. Because there were less than significant impacts, these impacts were not further analyzed in SEIR No. 339.

Project‐Specific Analysis:

As indicated in Response 3.6 (a)(i), the El Modeno and Peralta Hill faults are in proximity to the Proposed Project, both of which have the potential to induce strong seismic ground shaking. The Project’s design, engineering, and installation would be subject to all applicable seismic design requirements in place to protect infrastructure from the effects of seismic ground shaking. As described above, the proposed roadway improvements do not involve the construction of habitable structures, and its implementation would not increase the potential for human injury, loss, or death. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a spec ific development project. Any future development would be subject to CEQA and analyzed on a per project basis. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. For these reasons, impacts concerning strong seismic ground shaking would be less than significant, and the level of impact associated with the Proposed Project would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

7 California Department of Conservation, Seismic Hazard Zone Map for the Anaheim Quadrangle, Released April 15, 1998.

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iii) Seismic‐ related ground failure, including liquefaction?

Pr
evious Significance Determination: SEIR No. 339 concluded that impacts associated with seismic- relat
ed ground failure, including liquefaction would be less than significant following conformance with required codes and SEIR No. 332 MM 5.3-1 through MM 5.3-6. Because there were less than significant impacts, these impacts were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: According to the Orange General Plan Figure 5.6 -2 (Environmental and Natural Hazard Policy Map), portions of the Project Site generally east of the Orangewood Avenue/SR-57 Interchange are prone to liquefaction. Due to the nature of the Project ’s proposed improvements, settlement as the result of liquefaction following a seismic event would likely be minimal. Nonetheless, placement and compaction of fill would be subject to conformance with the City of Anaheim and City of Orange Grading Standards to the satisfaction of a qualified geotechnical engineer (soil engineer) in addition to SEIR No. 332 MM 5.3-1 through MM 5.3-4 and MM 5.3-6. SEIR No. 332 MM 5.3-5 pertain to habitable structures and thus is not applicable to the Proposed Project . The roadway improvements would not significantly expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving seismic -related ground failure. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development would be subject to CEQA and analyzed on a per project basis. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. Impacts concerning seismic-related ground failure would be less than significant following conformance with SEIR No. 332 MM 5.3-1 through MM 5.3-4 and MM 5.3-6, and the level of impact for the Proposed Project would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

iv) Landslides?

Previous Significance Determination: The Initial Study for the SEIR No. 339 concluded that the PTMLUP area does not contain any major slopes on or in the immediate vicinity which would represent a landslide hazard; thus, PTMLUP buildout would not involve impacts associated with landslides and no mitigation was necessary. Because there were no impacts, these resources were not further analyzed in SEIR No. 339.

Project‐Specific Analysis:

According to the Orange General Plan Figure 5.6 -2, t he Project Site is not located within an area susceptible to seismically -induced landslides. Therefore, no impacts associated with landslides would occur, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

b) Would the project result in substantial soil erosion or the loss of topsoil?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded soils within the PTMLUP have a slight erosion potential, but buildout would involve less than significant impacts concerning substantial soil erosion and loss of topsoil following conformance with existing regulatory

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requirements for erosion control. In addition, development projects involving one or more acres wo uld require compliance with a National Pollutant Discharge Elimination System (NPDES) permit and implementation of a stormwater pollution prevention plan (SWPPP) during construction for erosion control. Adherence to existing regulatory requirements would reduce erosion impacts to less than significant. Because there were less than significant impacts, these impacts were not further analyzed in SEIR No. 339.

Project‐Specific Analysis:

Soil erosion is most prevalent in unconsolidated alluvium and surficial soils and in areas that have slopes.

According to SEIR No. 339, the Project area includes soils with slight erosion potential. The proposed roadway improvements would occur along a generally flat segment of Orangewood Avenue where the potential for soil erosion would be minimal. However, construction activities occurring within the Santa Ana River associated with the roadway widening would displace top soils and temporarily increase the potential for displaced soils to be subject to wind and water erosion.

To
reduce the Project’s potential to result in loss of topsoil, the Project would be required to meet the grading standards identified by the City of Anaheim and City of O range, as applicable. Further, in accordance with NPDES requirements, Project implementation would require preparation of a SWPPP for approval prior to grading activities. The SWPPP would include site -specific best management practices (BMPs) to be imple mented with the Project to prevent erosion, minimize siltation from impacting downstream water bodies, and protect water quality . All grading operations, land clearing, loading, stockpiling, landscaping, and construction haul routes would also be subject to SCAQMD Rule 403, Fugitive Dust Emissions, as required by SEIR No. 339 MM 2 -2. Compliance with SCAQMD Rule 403, as well as preparation of a SWPPP would reduce the potential for on-si te and off-si
te erosion impacts. The proposed
amendments to the Genera l Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development would be subject to CEQA and analyzed on a per project b asis. Given that the permitted type and intensity of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. Therefore, impacts associated with erosion would be less than significant, and the level of impact for the Proposed Project would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

c) Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on‐ or off ‐site landslide, lateral spreading, subsidence, liquefaction or collapse?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that impacts associated with a geologic unit or soil that is unstable to be less than significant. Because there were less than significant impacts, these impacts were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: According to the SEIR No. 339, the near-su rface soils in the Platinum Triangle area are generally medium-de
nse, fine, and fine-to-me
dium-de
nse sand with occasional traces of gravel
and infrequent seams of silt. The expansion potential for these soils is considered low. These soils are part of hydrologic group A, which exhibits high infiltration properties. The Orange General Plan EIR does not identify the Project Site as located within an area subject to landslide hazards; refer also to Response

3.6 (a) (IV) above . However, portions of the Project Site east of the Orangewood Avenue/SR- 57

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Interchange (generally near the Santa Ana River) are prone to liquefaction according to the Orange General Plan EIR; refer also to Response 3.6 (a) (III) above. All Project improvements would be designed and constructed in conformance with the California Building Standards Code seismic engineering standards, as well as with City of Anaheim and City of Orange grading standards, as applicable, in addition to SEIR No. 332 MM 5.3-1 through MM 5.3-4 and MM 5.3-6. Pursuant to SEIR No. 332 MM 5.3-1, development activities within a seismic hazard zone would require preparation of a site-specific report in compliance with DMG Special Publication 117, Guidelines for Evaluating and Mitigating Seismic Hazards.

Impacts would be less than significant following conformance with SEIR No. 332 MM 5.3-1 through MM

5.3-4 and MM 5.3-6, and the level of impact would not increase from that identified in SEIR No. 339. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development would be subject to CEQA and analyzed on a per project basis. Given that the permitted type and intensity of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

d) Would the project be located on expansive soil, as defined in Table 18‐1‐B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 Appendix A.

Previous Significance Determination: The Initial Study for SEIR No. 339 indicated that the near-surface soils within the PTLMUP are generally medium -dense, fine and fine -to-medium sand with occasional traces of gravel and infrequent streams of silt. Based on these characteristics, the expansion potential for these soils is co nsidered low. In addition, development projects would require compliance with the California Building Standards Code and Anaheim Municipal Code Title 17. Adherence to existing regulatory requirements would reduce expansive soil impacts to less than significant. Therefore, this topic was not further addressed in SEIR No. 339.

Project‐Specific Analysis: Expansive soils are those that undergo volume changes as moisture content fluctuates, swelling substantially when wet or shrinking when dry. Soil expansion can damage structures by cracking foundations, causing settlement, and distorting structural elements. According to SEIR No. 339 Addendum No. 7, the expansion potential for surface soils within the Project area (primarily medium- de
nse, fine, and fine -to-me
dium sand with occasional traces of gravel and infrequent seams of silt) is considered low. As noted previously, the roadway improvements would not significantly expose people or property to risk of expansive soils . Nonetheless, roadway construction would occur based on the recommendations of a geotechnical engineer as part of the final design process. Conformance with such measures would ensure impacts concerning expansive soils would be less than significant , and the level of impact would not increase from that identified in SEIR No. 339. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific developme nt project. Any future development would be subject to CEQA and analyzed on a per project basis. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. Therefore, the level of impact for the Proposed Project would not increase from that identified in SEIR No. 339.

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Significance Determination: No substantial increase in the level of impact from previous analysis.

e) Would the project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?

Previous Significance Determination: The Initial Study for the SEIR No. 339 concluded that the Platinum Triangle would not use of septic tanks or alternative sewer disposal systems ; thus, PTMLUP buildout would not involve impacts associated with septic tanks or alternative sewer disposal systems and no mitigation was necessary. Therefore, this topic was not further addressed in SEIR No. 339.

Project‐Specific Analysis: As a roadway widening project, alternative wastewater disposal systems are not proposed nor req uired. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization portion of this project reflect anticipated future development of these areas, but not a specific development project. Any future development would be subject to CEQA and analyzed on a per project basis. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact w ould not increase from that identified in SEIR No. 339. Therefore, n o impact would occur, and the level of impact from the Proposed Project would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

f) Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the PTMLUP area has already been disturbed and thus the potential for any subsurface paleontological resources is remote; thus, PTMLUP buildout would not impact pa leontological resources and no mitigation was necessary. Because there were no impacts, these resources were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: The Project site includes a fully-improved segment of Orangewood Avenue and area along the Santa Ana River, surrounded by developed uses. In addition, the Project’s proposed Santa Ana River Trail improvements would occur within a heavily disturbed segment of the River that has been subject to channelization and frequent human interference. As the Project Site is located within a developed area subject to past disturbance, the potential for the inadvertent discovery of paleontological resources is considered remote. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization portion of this project reflect anticipate d future development of these areas, but not a specific development project. Any future development would be subject to CEQA and analyzed on a per project basis. Therefore, the Project would not impact paleontological resources, and the level of impact would not increase from that identified in SEIR No. 339.

The Project Site is situated within a developed and urbanized area, and there are no unique geologic features within the Project vicinity. Therefore, the Project would not impact unique geologic features, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

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3.7.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

SEIR No. 332 includes measures to reduce potential impacts associated development and infrastructure improvements within the Platinum Triangle. The following measures from SEIR No. 332 are applicable to the Proposed Project.8 Any modifications to the original measures are shown in strikethrough for deleted text and new, inserted text is underlined.

5.3-1 Prior to approval of a grading plan, if within a Seismic Hazard Zone, the property owner/developer City shall submit to the Public Works Department a site -specific report in compliance with DMG Special Publication 117, Guidelines for Evaluating and Mitigating Seismic Hazards in California. The report shall be prepared by an engineering geologist and geotechnical engineer. All grading shall be in conformance with Title 17 of the Anaheim Municipal Code.

5.3-2 During the Plans, Specifications, and Estimate phase Prior to issuance of a building permit, the property owner/developer City shall submit to the Planning Department, Building Division,Public Works Department, Development Services Division, for review and approval, detailed foundation design information for the proposed structures buildings, prepared by a civil engineer, based on recommendations of a geotechnical engineer.

5.3-3 During the Plans, Specifications, and Estimate phase Prior to issuance of a building permit, the property owner/developer City shall submit to the Public Works Department, Development Services Division,Planning Department, Building Division, a report prepared by a geotechnical engineer for review and approval which shall investigate the subject foundation excavations.

5.3-4 During the Plans, Specifications, and Estimate phase Prior to issuance of a building permit, the property owner/developer City shall submit to the Public Works Department, Development Services Division,Planning Department, Building Division, plans showing that the proposed structure(s) has been analyzed for earthquake loading and designed according to the most recent seismic standards in the Uniform Building Code adopted by the City of Anaheim.

5.3-6 On-going during grading operations, the p roperty owner/developer City shall implement standard practices from City Ordinance (Title 17) and policies to the satisfaction of the Public Works Department, Field Engineering Division.

Mitigation Measures from SEIR No. 339

SEIR No. 339 does not include mitigation measures for geology and soils.

8 Mitigation measure numbering corresponds to the Final Platinum Triangle Subsequent Environmental Impact Report Appendix A, Updated and Modified Mitigation Monitoring Program Number 106A, dated August 2005.

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3.8 GREENHOUSE GAS EMISSIONS

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the
environment?

b. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases?


a) Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?

Previous Significance Determination: SEIR No. 339 concluded that PTMLUP buildout had the potential to generate greenhouse gas (GHG) emissions, either directly or indirectly, that may have a significant impact on the environment. Specifically, SEIR No. 339 found that the project evaluated in the SEIR would generate substantially more GHG emissions compared to the adopted PTMLUP and would cumulatively contribute to climate change impacts in California. Mitigation measures from several environmental sections of SEIR No. 339 were identified to reduce GHG emissions, including: MM 2-3, MM 2-5, MM
2-6,
MM 9-1,
MM 9-2,
MM 9-12,
MM 9-14,
MM 10-7, M
M 10-9,
MM 10-12, MM 1
0-13,
MM 10-14,
MM 10-
18, MM 10 -19,
MM 10 -20
, MM 10 -21,
MM 10 -22, a
nd MM 10 -24.

Despite implementation of the
abovementioned mitigation measures , impacts related to GHG emissions were determined to remain significant and unavoidable, and a Statement of Overriding Considerations was adopted by the City Council when SEIR No. 339 was certified.

Project‐Specific Analysis: Roadway construction would generate GHG emissions, as GHGs would be emitted through the operation of construction equipment and from worker and vendor vehicles, each of which typically use fossil- based fuels to operate. The combustion of fossil -based fuels creates GHG emissions such as carbon dioxide (CO
2), methane (CH 4), and nitrous oxide (N 2O). Furthermore, CH4 is emitted during the fueling of heavy equipment. Despite the Project’s potential to generate construction- related GHGs, the changes proposed under this Addendum would not significantly worsen the Project’s potential to result in direct or indirect construction-related GHG emissions. Construction activities would be similar to those identified under SEIR No. 336 and impacts would be less than significant.

None of the Project components identified in Section 2.3 , Proposed Project would represent a new permanent stationary or mobile sources of GHG emissions. The Project does not include any new buildings which would represent a permanent source of stationary or energy source GHG emissions.

Further, once completed, the Project would not result in a permanent increase in traffic; refer to Section

3.17. Project implementation would accommodate existing and predicted traffic demands associated with buildout of the PTMLUP and would not directly generate new traffic or increase the number of vehicles along the roadway. For these reasons , the Project would not generate quantifiable GHG emissions from long-term operations and SEIR No. 339 MM 2-3, MM 2-5,
MM 2-6,
MM 9-1,
MM 9-2,
MM
9-12,
MM 9-14,
MM 10-7, MM
10-9, MM
10-12, M
M 10-13,
MM 10-14,
MM 10-18,
MM 10-19,
MM 10-

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21, MM 10-22, and MM 10-24 are not applicable to the Proposed Project. The Project would demonstrate conformance with MM -10-20, included below, which requires preparation of a Demolition and Import/Export Plan which identifies offsite locations for materials export and disposal. Additionally, the Project improves a non-motorized transportation option by providing a sidewalk for pedestrians as well as expanded bicycle facilities.

Th
e proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. The proposed amendments reflect anticipated future development of these areas, which is similar in intensity to what the General Plan already permits. Currently the General Plan designates the subject properties for Mixed Use Urban Core and Open Space land use. The proposed amendments for Area 1 and 1A would spread the intensities permitted General Plan Mixed -Use Urban Core land use designation over a slightly larger area; however, the amendments would not increase the maximum intensities permitted by the General Plan for the Platinum Triangle. The proposed amendments for Area 2 would change the land use designation for Open Space to Parks; the General Plan permits both uses at the same maximum FAR of 0.10. There would be no change in the General Plan designations for the remainder of the area subject to the reorganization. Any future development of the area subject to the reorganization would be subject to CEQA and analyzed on a per project basis. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

Therefore, the Project would not result in new permanent stationary or mobile sources of GHG emissions and the level of impact from the Project would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?

Previous Significance Determination: SEIR No. 339 concluded that the Platinum Triangle would not conflict with an applicable plan, policy, or regulation adopted for reducing the emissions of GHGs, as the Revised Platinum Triangle Expansion Project would be consistent with Statewide and region al GHG reduction goals. A less than significant impact was identified.

Project‐Specific Analysis: Assembly Bill ( AB) 32 is the legal mandate requiring that Statewide GHG emissions be reduced to 1990 levels by 2020. In addition, Statewide goals for GHG reductions in the years beyond 2020 have been recently codified into State law with the passage of Senate Bill (SB) 32. Signed into law on September 2016, SB 32 codifies the 2030 target in the recent Executive Order B 30 15 (40 percent below 1990 levels by 2030). The bill authorizes the State board to adopt an interim GHG emissions level target to be achieved by 2030. SB 32 states that the intent is for the Legislature and appropriate agencies to adopt complementary policies which ensure that the long-term emissions reductions advance specified criteria. However, a t the time of writing this Initial Study, no specific policies or emissions reduction mechanisms have been established.

SCAG’s 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Governments – Connect SoCal (2020-2045 RTP/SCS), adopted September 3, 2020, is a long -range visioning plan that balances future mobility and housing needs with economic, environmental, and public health goals. The 2020-2045 RTP/SCS embodies a collective vision for the region’s future and is developed with input from local governments, county transportation commissions,

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tribal governments, nonprofit organizations, businesses, and local stakeholders in Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura Counties. The 2020 -2045 RTP/SCS is forecast to help California reach its GHG reduction goals by reducing GHG emissions from passenger cars by eight percent below 2005 levels by 2020 and 19 percent by 2035 in accordance with the most recent CARB targets adopted in March 2018. The 2020-2045 RTP/SCS contains over 4,000 transportation projects, including highway improvements, railroad grade separations, bicycle lanes, new transit hubs, and rep lacement bridges. These future investments were included in county plans developed by the six -county transportation commissions and seek to reduce traffic bottlenecks, improve the efficiency of the region’s network, and expand mobility choices. The 2020-2045 RTP/SCS is an important planning document for the region, allowing project sponsors to qualify for Federal funding. In addition, the 2020 -2045 RTP/SCS is supported by a combination of transportation and land use strategies that help the region achieve State GHG emission reduction goals and Federal CAA requirements, preserve open space areas, improve public health and roadway safety, support the vital goods movement industry, and utilize resources more efficiently. The Proposed Project’s consistency with the 2020-2045 RTP/SCS goals is analyzed in detail in Table 3.8-1, Consistency with SCAG’s 2020 -2045 Regional Transportation Plan/Sustainable Communities Strategy Goals.

Table 3.8-1
Consistency with SCAG’s 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy Goals

SCAG Goals Compliance With Goal
Goal 1: Encourage regional economic
prosperity and global competitiveness
Not Applicable: Due to the nature of the proposed improvements, Goal 1 is not a project-specific goal which would be applicable to the Project.

Goal 2: Improve mobility, accessibility,
reliability, and travel safety for people and
goods
Consistent: The Project would widen Orangewood Avenue from a five-lane facility to six lanes and associated bicycle lane/sidewalk to accommodate existing and predicted traffic levels associated with buildout of the PTMLUP.

Further, the proposed improvements would follow all applicable safety standards in applicable regulatory documents. Pedestrian walkways and bicycle routes must follow safety precautions and standards established by local (e.g., City of Anaheim and City of Orange) and regional (e.g., SCAG) agencies. Roadways for motorists must follow safety standards established for the local and regional plans. Thus, the Project would improve mobility and accessibility, as well as ensure travel safety and reliability for all people and goods in the region and would be consistent with Goal 2.

Goal 3: Enhance the preservation, security,
and resilience of the regional transportation
system
Consistent: Security issues involving roadways and evacuations are addressed in the City of Anaheim and City of Orange’s emergency management plans developed in accordance with State and Federal - mandated emergency management regulations. The Cities of Anaheim and Orange would continue to monitor Orangewood Avenue to determine the adequacy and safety of this roadway segment. Thus, the Project would enhance the preservation, security, and resilience of the transportation system and would be consistent with Goal 3.

Goal 4: Increase person and goods movement
and travel choices within the transportation
system
Consistent: The Project would widen Orangewood Avenue from a five -lane facility to six lanes to accommodate existing and predicted traffic levels associated with buildout of the PTMLUP. Additionally, the Project would accommodate bicycle and sidewalk facilities. Thus, Project implementation would increase person and goods movement, as well as travel choices, within the transportation system and the Project would be consistent with Goal 4.

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Table 3.8-1 (continued)
Consistency with SCAG’s 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy Goals

SCAG Goals Compliance With Goal
Goal 5: Reduce greenhouse gas emissions
and improve air quality
Consistent: The Project improves a non-motorized transportation option by providing a sidewalk for pedestrians and expands existing bicycle facilities .

Therefore, the Project would encourage non- motorized transportation, reduce GHG emissions, and improve air quality. Thus, the Project would be consistent with Goal 5.

Goal 6: Support healthy and equitable
communities
Consistent: Refer to Response to Goal 5. T he Project would support alternative modes of transportation, including walking and bicycling. As a result, the Project would reduce GHG emissions and improve air quality.

Therefore, the Project would promote healthy and equitable communities and be consistent with Goal 6.

Goal 7: Adapt to a changing climate and
support an integrated regional development
pattern and transportation network
Consistent: The Project would widen Orangewood Avenue from a five -lane facility to six lanes to accommodate existing and predicted traffic levels associated with buildout of the PTMLUP , as well as accommodate bicycle and sidewalk facilities . However, the Project would not directly generate new traffic or increase the number of vehicles along the roadway. Therefore, the Project would encourage climate change adaption by reducing GHG emissions and encouraging non- motorized transportation. The Project improvements would support the regional transportation network by accommodating existing and predicted traffic demands . Thus, the Project would be consistent with Goal 7.

Goal 8: Leverage new transportation
technologies and data-driven solutions that
result in more efficient travel
Consistent: The Project would support efficient travel by widening Orangewood Avenue to accommodate existing and predicted traffic demands. Thus, the Project would be consistent with Goal 8.

Goal 9: Encourage development of diverse
housing types in areas that are supported by
multiple transportation options
Not Applicable: Goal 9 focuses on housing supply and therefore does not apply to the proposed roadway improvement and annexation Project.

Goal 10: Promote conservation of natural and
agricultural lands and restoration of habitats
Not Applicable: The Project does not include natural or agricultural lands.

Therefore, Goal 10 does not apply to the proposed Project.

Source: Southern California Association of Governments, 2025-2040 Regional Transportation Plan/Sustainable Communities Strategy – Connect SoCal, September 3, 2020.

As proposed, the Project would not conflict with the 2020-2045 RTP/SCS goals. Thus, the Project would not conflict with an adopted plan, policy, or regulation pertaining to GHGs. Further, it is acknowledged that the proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. The proposed amendments reflect anticipated future development of these areas, which is similar in intensity to what the General Plan already permits. Currently the General Plan designates the subject properties for Mixed Use Urban Core and Open Space land use. Th e proposed amendments for Area 1 and 1A would spread the intensities permitted General Plan Mixed -Use Urban Core land use designation over a slightly larger area; however, the amendments would not increase the maximum intensities permitted by the General Plan for the Platinum Triangle. The proposed amendments for Area 2 would change the land use designation for Open Space to Parks; the General Plan permits both uses at the same maximum FAR of 0.10. There would be no change in the General Plan designations f or the remainder of the area subject to the reorganization. Any future development of the area subject to the reorganization would be subject to CEQA and analyzed on a per project basis. Given that the permitted

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type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. Therefore, the Proposed Project would not result in new GHG impacts different from those identified for SEIR No. 339 and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

3.8.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

Refer to the Mitigation Measures from SEIR No. 339 below, which are based on adopted Mitigation Measures from SEIR No. 332.

Mitigation Measures from SEIR No. 339

SEIR No. 3 39 includes measures to reduce potential impacts associated the development and infrastructure improvements within the Platinum Triangle. SEIR No. 339 also includes measures related to air quality, transportation and traffic, and utilities and service systems which would reduce GHG emissions; refer to Sections 3.3 , Air Quality ; 3. 17; and 3.19, Utilities and Service Systems of this Addendum. The following measures from SEIR No. 339 are applicable to the Proposed Project.9 Any modifications to the original measures are shown in strikethrough for deleted text and new, inserted text is underlined. In addition to Air Quality MM 2-3 a nd MM 2-5, de scribed above, the following measure is applicable to the Proposed Project:

MM 10-20 P rior to the approval of each grading plan (for import/export plan) and prior to issuance of demolition permits (for demolition plans), the property owner/developer City shall submit a Demolition and Import/Export Plans, if determined to be necessary by the Public Works Department, Traffic Engineering Division and/or Street and Sanitation Division. The plans shall include identification of off
-sit
e locations for material export from the project and options for disposal of excess material. These options may include recycling of materials on-sit e, sale to
a broker or contractor, sale to a project in the vicinity or transport to an environmentally cleared landfill, with at tempts made to move it within Orange County. The property owner/developer City shall offer recyclable building materials, such as asphalt or concrete for sale or removal by private firms or public agencies for use in construction of other projects, if all cannot be reused on the project siteProject Site.

9 Mitigation measure numbering corresponds to Platinum Triangle Master Land Use Plan Appendix C, Updated and Modified Mitigation Monitoring Program Number 106C.

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3.9 HAZARDS AND HAZARDOUS MATERIALS

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?

b. Create a significant hazard to the public or the
environment through reasonably foreseeable upset and
accident conditions involving the release of hazardous
materials into the environment?

c. Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within one- quarter mile of an existing or proposed
school?

d. Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or the environment?

e. For a project located within an airport land use plan or, where such a plan has not been adopted, within two
miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?

f. Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?

g. Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?


This section is primarily based on the Phase I Environmental Site Assessment for the Orangewood Avenue Improvements Project located in the Cities of Anaheim and Orange, California (Phase I ESA), prepared by Michael Baker International, dated October 2017 ; refer to Appendix C, Phase I Environmental Site Assessment.

a) Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that PTMLUP buildout would allow for the continued operation of businesses that use and store various hazardous materials. In addition, the PTMLUP has designated the northern periphery of the PTMLUP area as industrial. These areas may handle hazardous materials; h owever, businesses are required to obtain permits and maintain records regarding the storage, use and disposal of hazardous material. The Initial Study concluded that development of the PTMLUP would not change the existing condition of the project area and/or increase the use of hazardous materials in the area, and that adhering to the existing permitting process would ensure that less than significant hazard to the public or the environment occur.

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Because these impacts were considered less than significant, they were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: Roadway construction may involve temporary hazards related to hazardous materials transport and use, including those used for typical construction activities (i.e., diesel fuel, motor oil, etc.). The Project’s construction contractor(s) would be required to uphold standard best management practices to ensure that all hazardous materials are stored, transported, used, and disposed of in accordance with Federal and State law. Conformance with these standards would effectively avoid and minimize significant hazards related to the transport, use, and disposal of hazardous materials and would reduce the Project ’s impacts to less than significant levels , and the level of impact wou ld not increase from that identified in SEIR No. 339. Orangewood Avenue would operate consistent with its existing condition relative to routine transport of hazardous materials.

The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. The proposed amendments reflect anticipated future development of these areas, which is similar in intensity to what the General Plan already permits. Currently the General Plan designates the subject properties for Mixed Use Urban Core and Open Space land use. The proposed amendments for Area 1 and 1A would spread the intensities permitted General Plan Mixed -Use Urban Core land use designation over a slightly larger area; however, the amendments would not increase the maximum intensities permitted by the General Plan for the Platinum Triangle. The proposed amendments for Area 2 would change the land use designation for Open Space to Parks; the General Plan permits both uses at the same maximum FAR of 0.10. There would be no change in the General Plan design ations for the remainder of the area subject to the reorganization. Any future development of the area subject to the reorganization would be subject to analysis , pursuant to CEQA, of hazards and hazardous materials impacts and measures would be proposed to reduce impacts, if required. However, the amendments do not involve a land use which would create a significant hazard to the environment due to the routine transport, use, or disposal of hazardous materials. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. Thus, Project operations would not create a hazard related to the transport, use, and disposal of hazardous materials, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

b) Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the Platinum Triangle would not create a significant hazard to the public or environment due to accidental release of hazardous materials following conformance with existing Federal and State regulations. To further reduce risk of accidental release of hazardous materials into the environment, the Initial Study for SEIR No. 339 recommends implementation of MMP No. 106A MM 5.4-1 through MM 5.4-7, prepared for SEIR No 332.

Because these impacts were considered less than significant, they were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: Refer to Response 3.8 (a). Project construction could result in the accidental release of hazardous substances such as spilling of petroleum-based fuels, lubricants, and other materials

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used for construction equipment. Use, storage, transport, and disposal of these materials would be subject to standard construction standards safety procedures and controls that would avoid and minimize the potential for accidental release of hazardous substances into the environment. Standard construction best management practices would be observed such that any hazardous materials released are appropriately contained and remediated as required by local, State, and Federal law. Conformance with these standards would reduce impacts related to the accidental release of hazardous materials into the environment to less than significant levels, and the level of impact would not increase from that identified in SEIR No. 339.

In accordance with SEIR No. 332 MM 5.4 -6, Michael Baker prepared a Phase I ESA in conformance with the scope and limitations of ASTM International (ASTM) E 1527-13 Standard Practice for Environmental Site Assessments. The Phase I ESA evaluated the potential for known hazardous sites in the area to potentially affect the subject site.

Recognized Environmental Conditions (RECs) indicates the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: 1) due to release to the environment; 2) under conditions indicative of a release to the environment; or 3) under conditions that pose a material threat of a future release to the environment. De minimis conditions are not considered RECs.

The Phase I ESA identified the following two RECs in connection with the Project Site:

• Aerially Deposited Lead: Aerially deposited lead refers to lead deposited on highway shoulders from past leaded fuel vehicle emissions. Based on historical aerial photographs and United States Geological Survey topographic maps, SR -57 was constructed in 1977. The potential for lead contamination to exist within exposed soils on -site due to aerially deposited lead is likely. It is Michael Baker's opinion that there is a REC on the subject site due to aerially deposited lead.

• Groundwater Contamination: The adjacent property located at 2023 Collins Street (approximately 2,420 feet up gradient of the Project Site ) was found to have groundwater contamination extending to a maximum distance of 6,500 feet down gradient, which includes the Project Site and areas of propose right -of-way acquisition. For this reason, it is likely that the Project Site is underlain by contaminated groundwater. However, the groundwater is anticipated to be greater than 80 feet below ground surface; therefore, proposed construction activities are not anticipated to encounter groundwater.

Aerially Deposited Lead

Ground disturbance activities associated with Project construction activities could subject const ruction workers to aerially deposited lead. However, ground disturbance and spoils removal, transport, and cleanup procedures would conform to California Department of Toxic Substances Control (DTSC) guidelines. In compliance with SEIR No. 332 MM 5.4-1, if aerially deposited lead is discovered during site preparation or construction, the City of Anaheim would ensure that the identified hazardous waste and/or hazardous material is handled and disposed of in the manner specified by the State of California Hazardous Substances Control Law (Health and Safety Code, Division 20, Chapter 6.5) and according to the requirements of the California Administrative Code, Title 30, Chapter 22. In addition, the City would report the finding of hazardous waste to the Orange County Health Care Agency and Anaheim Fire Department (AFD). Conformance with these standards would reduce impacts related to aerially deposited lead to less than significant levels, and the level of impact would not increase from that identified in SEIR No. 339.

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Groundwater Contamination

Ground disturbance activities associated with Project construction activities could result in the exposure of construction workers to contaminated groundwater. If dewatering discharge is piped to storm drains, the requirements of the De Minimis Waste Discharge Requirements for the Santa Ana Region (Order No.

R8-2015-0004, NPDES No. CAG998001) would govern dewatering activities during construction.

Compliance with Order No. 2003 -0003-DWQ/Order No. R8 -2015-0004, NPDES No. CAG998001 would ensure Project construction dewatering would not cause State waste discharge and Federal NPDES permit requirements to be exceeded . SEIR No. 332 MM 5.4 -1 would further reduce impacts related to groundwater contamination to less than significant levels, and the level of impact would not increase from that identified in SEIR No. 339.

In addition to the potential for aerially deposited lead and groundwater contamination, p ortions of the Santa Ana River bridge overpass may include asbe stos containing materials (ACM) and lead based paint (LBP) and existing traffic striping along Orangewood Avenue may also include LBP. The Phase I ESA does not identify a REC for ACM or LBP; however, these hazardous materials are likely present within the Project boundaries based on historical application. Thus, there is potential for accidental release during ground disturbance activities. All disturbance activities would conform to DTSC guidelines as well as SEIR No. 332 MM 5.4-1 and MM 5.4-7. SEIR MM 5.4-7 requires preparation of an asbestos survey. If ACM is identified, SEIR No. 332 MM 5.4- 7 requires remediation and mitigation procedures conform with the Remediation Procedures Report, and in accordance with Federal, State, and local law. SEIR N o. 332 also requires that structures constructed prior to 1973 are screened for LBP prior to demolition. If LBP is identified, SEIR No. 332 MM 5.4-7 requires it is mitigated in accordance with t he procedures set forth in the Remediation Procedures Report. Conformance with DTSC Guidelines, as well as SEIR No. 332 MM 5.4- 1 and MM 5.4- 7 would ensure impacts related to accidental release of ACM and LBP are less than significant, and the level of impact would not increase from that identified in SEIR No. 339.

The Orangewood Avenue and the local roadway system would continue to operate as it does presently, except for the additional travel lane and other related Project improvements. Roadway maintenance activities could require limited quantities of hazardous materials, as needed; however, such activities would be temporary in nature and would be similar to the roadway segment’s existing maintenance practices. No long-term impacts would occur in this regard, and the level of impact would not increase from that identified in SEIR No. 339.

The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. The proposed amendments reflect anticipated future development of these areas, which is similar in intensity to what the General Plan already permits. Currently the General Plan designates the subj ect properties for Mixed Use Urban Core and Open Space land use. The proposed amendments for Area 1 and 1A would spread the intensities permitted General Plan Mixed -Use Urban Core land use designation over a slightly larger area; however, the amendments wo uld not increase the maximum intensities permitted by the General Plan for the Platinum Triangle. The proposed amendments for Area 2 would change the land use designation for Open Space to Parks; the General Plan permits both uses at the same maximum FAR o f 0.10. There would be no change in the General Plan designations for the remainder of the area subject to the reorganization. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. Therefore, no

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long-term impacts would occur in this regard, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

c) Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one‐ quarter mile of an existing or proposed school?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the use and handling of hazardous materials, substances, and wastes within the PTMLUP would be subject to conformance with appropriate State and Federal rules and regulations through the permitting process and that no unauthorized use of hazardous materials would be allowed. Thus, although proposed mixed- use developments could emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or wastes within one -quarter mile of an existing or proposed school, impacts would be less than significant. Bec ause these impacts were considered less than significant, they were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: The nearest school, Sycamore Elementary School, is located approximately

0.29-mile to the southeast of the Project Site a t 340 Main Street in the City of Orange . No schools are located within one-quarter mile of the Project Site. Thus, no impacts associated with emitting hazardous emissions or handling hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school would result, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

d) Would the project be located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the Platinum Triangle would not involve significant impacts concerning hazardous materials sites following conformance with existing Federal and State regulations that govern ha zardous ma terial and waste management. To further reduce risk of accidental release of hazardous materials into the environment, the Initial Study for SEIR No. 339 recommends implementation of MMP No. 106A MM 5.4-1 through MM

5.4-7, prepared for SEIR No. 332. Because these impacts were considered less than significant, they were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: According to the Phase I ESA , the Project Site is not listed pursuant to Government Code Section 65962.5 (also known as the “Cortese Listing”). No impacts would result in this regard and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?

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This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 Appendix A.

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the PTMLUP is not affected by the Airport Land Use Plan for the Los Alamitos Armed Forces Reserve Center or Fullerton Municipal Airport ; thus, PTMLUP buildout w ould not result in a safety hazard for people residing or working in the project area and no mitigation was necessary. Because there were no impacts, they were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: The Initial Study for SEIR No. 339 found that the PTMLUP area is not located within an airport land use plan, nor is the area within two miles of a public airport. As a roadway widening and annexation project, the Project would not involve the installation of aboveground structures that could represent a safety hazard to air traffic. Therefore, no impacts associated with public airport safety hazards would occur, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

f) Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the City of Anaheim’s emergency preparedness plan complied with State law and interfaced with other cities and counties within Southern California and that the City also participates in the Standardized Emergency Management System (SEMS). The Initial Study concluded that although PTMLUP buildout would intensify land uses within the Project area, impacts would be less than significant since all new development would be required t o accommodate emergency vehicle. Because these impacts were considered less than significant, they were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: The City of Anaheim’s Hazard Mitigation Plan and the City of Orange’s Multi- Hazard Functional Plan were prepared in response to the Disaster Mitigation Act of 2000 to outline the operations and activities that would occur in the event of a dis aster. Although the Project would temporarily impact traffic flow along Orangewood Avenue during construction, Project construction would not substantially interfere with traffic circulation as Project construction would occur over a limited timeframe and traffic lanes in each direction along Orangewood Avenue would remain open. No new development is proposed within the Santa Ana River reorganization area as part of this Project.

Over the long term, the roadway widening would improve traffic flows along the affected segment and therefore may enhance the roadway’s function as an emergency access route, if necessary. The proposed Orangewood Avenue roadway widening is anticipated to improve area circulation opportunities. Project implementation woul d not require revisions to the City of Anaheim or City of Orange’s adopted emergency response plans. If development is proposed in the Santa Ana River reorganization area in the future, analysis of hazards would be conducted at that time and measures would be proposed to reduce impacts, if required. Thus, impacts concerning emergency response or evacuation plans would be less than significant, and the level of impact would not increase from SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

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g) Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 Appendix A.

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that PTMLUP buildout would not expose people or structures to significant risk of loss, injury or death involving wildland fires since the PTMLUP area is developed and no undeveloped wildland areas are in or adjacent to the PTMLUP area. Because there were no impacts, they were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: The Project Site is not identified as a Wildland Fire Hazard Area by Figure

5.6-2 (Environmental and Natural Hazard Policy Map) of the Orange General Plan EIR. The Project Site is primarily surrounded by urban development in addition to a channelized portion of the Santa Ana River.

As a roadway improvement project, the Project would not involve the construction of habitable structures which would expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a s pecific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted location, type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. Therefore, no impacts associated with wildland fires would occur, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

3.9.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

SEIR No. 332 includes measures to reduce potential impacts associated development and infrastructure improvements within the Platinum Triangle. The following measures from SEIR No. 332 are applicable to the Proposed Project.
10 Any modifications to the original measures are shown in strikethrough for deleted text and new, inserted text is underlined.

5.4-1 On-going during demolition and construction, in the event that hazardous waste is discovered during site preparation or construction, the property owner/developer City shall ensure that the identified hazardous waste and/or hazardous material is handled and disposed of in the manner specified by the State of California Hazardous Substances Control Law (Health and Safety Code, Division 20, Chapter 6.5) and according to the requirements of the California Administrative Code, Title 30, Chapter 22. In addition, the property owner/developer City shall report the finding of hazardous waste to the Orange County Health Care Agency and Anaheim Fire Department.

10 Mitigation measure numbering corresponds to the Final Platinum Triangle Subsequent Environmental Impact Report Appendix A, Updated and Modified Mitigation Monitoring Program Number 106A, dated August 2005.

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5.4-2 On-going during project operation, the applicant City shall handle and dispose of all hazardous materials and wastes during the operation and maintenance of facilities in accordance with the State codes identified in Mitigation Measure No. 5.4-1 and under Anaheim Fire Department supervision.

5.4-6 Prior to issuance of grading permits for each development project, a Phase I Site Assessment shall be prepared by the property owner/developer City and submitted to the City of Anaheim Public Works Department, Development Services Division, for review and approval. If actual or potential impacts are identified by the Phase I, a Phase II ESA will be completed for the site by the owner/developer City and the results will be submitted to the Planning Department.

During the Phase II ESA, samples from potential areas of concern will be collected and submitted for laboratory analysis to confirm the nature and extent of potential impacts. If hazardous materials are identified during the site assessments, the property owner/developer City shall notify the finding to the Anaheim Fire Department and the appropriate response/remedial measures will be implemented in accordance with the directives of the OCHCA and/or the Regional Water Quality Control Board (RWQCB), as appropriate. If soil is encountered during site development that is suspected of being impacted by hazardous materials, work will be halted and site conditions will be evaluated by a qualified environmental professional. The results of the evaluation will be submitted to OCHCA and/or RWQCB, and the appropriate response/remedial measures will be implemented, as directed by OCHCA, RWQCB, or other applicable oversight agency, until all specified requirements of the oversight agencies are satisfied and a no-further-action status is attained.

5.4-7 Prior to issuance of a grading permit or a demolition permit for any buildingDuring the Plans, Specifications, and Estimate phase, an asbestos survey shall be conducted and submitted to the Planning Department, Building Division,Public Works Department, Development Services Division, by the property owner/developer City. If the materials are found to contain asbestos fibers, demolition shall be conducted in accordance with the remediation and mitigation procedures detailed in Remediation Procedures Report, and in accordance with Federal, State, and local law. Buildings Structures constructed prior to 1973 shall be screened for lead- based paint prior to demolition. If lead -based paint is identified, it shall be mitigated in accordance with the procedures set forth in the Remediation Procedures Report.

Mitigation Measures from SEIR No. 339
SEIR No. 339 does not include mitigation measures for hazards and hazardous materials.

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3.10 HYDROLOGY AND WATER QUALITY

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Violate any water quality standards or waste discharge requirements or otherwise substantially degrade
surface or groundwater quality?

b. Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge such
that the project may impede sustainable groundwater
management of the basin?

c. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the
course of stream or river or through the addition of
impervious services, in a manner which would:

1) Result in substantial erosion or siltation on- or
off-site?
2) Substantially increase the rate or amount of
surface runoff in a manner which would result
in flooding on- or offsite?

3) Create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide
substantial additional sources of polluted
runoff?

4) Impede or redirect flood flows?
d. In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation? 
e. Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater
management plan?


A Basis of Design Report Santa Ana River at Orangewood Avenue Bridge Crossing, Anaheim, California Scour Analysis ( Basis of Design Report ) was prepared by Michael Baker in March 2022 . T his report is included as Appendix D, Basis of Design Report, and is summarized below.

a) Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 Appendix A.

Pr
evious Significance Determination: The Initial Study for SEIR No. 339 concluded that compliance with current water quality regulations associated with the City of Anaheim’s Local Implementation Plan, the Orange County Drainage Area Management Plan (DAMP), and the County area -wid e Storm Water

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Runoff Permit would reduce potential water quality impacts to a less than significant level. Because these impacts were considered less than significant, they were not further analyzed in SEIR No. 339.

Project‐Specific Analysis:

CONSTRUCTION-RELATED IMPACTS

Surface water quality is subject to Federal, State, and local water quality requirements administered and enforced by the EPA, the California State Water Resources Control Board (SWRCB), and the RWQCB with cooperation from each county. The principal law governing pollution of the nation’s surface waters is the CWA (formerly the Federal Water Pollution Control Act). Under the CWA, regulatory requirements for industrial and municipal dischargers were set, as well as requirements for states to adopt water quality standards.

The P
roposed Project would widen an existing segment of Orangewood Avenue to accommodate a new westbound travel lane and related improvements. The roadway improvements would increase impervious surface areas along the affected segment of Orangewood Avenue which could consequently increase the potential for surface runoff. The Project would be subject to conformance with SEIR No. 339 MM 3-2,

which requires compliance with NPDES General Construction Permit requirements, including preparation of a SWPPP and incorporation of sediment control BMPs to reduce the potential for offsite and downstream water quality impacts; refer also to Response 3.6 (b) above and SEIR No. 339 MM 3-2 below.

Implementation of the SWPPP wo uld reduce potential runoff and pollutants associated with Project construction activities to the maximum extent feasible. Further, grading activities associated with Project construction would be required to demonstrate conformance with Anaheim Municipal Code Chapter 17.04, Grading, Excavations, Fills, Watercourses, and the City of Orange Grading Ordinance (Orange Municipal Code Chapter 16.40). Following conformance with SEIR No. 339 MM 3-2, as well the Anaheim Municipal Code and Orange Municipal Code grading requirements, the Project’s construction-related impacts to water quality standards would be less than significant, and the level of impact would not i ncrease from that identified in SE IR No. 339. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

LO
NG-TER

M OPERATIONAL IMPACTS

Al
though the Proposed Project is not exempt from the requirements of the Orange County Model Water Quality Management Plan (WQMP) , the specific structural items, typically included in a WQMP for mitigating the impacts of additional impervious surfaces created by a project, would be constructed as part of the adjacent Orangewood Avenue Improvement Project (SCH #2004121045) located to the west of the Proposed Project . As the Orangewood Avenue Improvement Project would precede the implementation of this Proposed Project, this Proposed Project’s additional impervious area would be sufficiently mitigated when its construction begins. Furthermore, the Project proposes improvements to the local drainage system to capture flow from the widened bride and roadway improvements and convey local drainage flow to the Santa Ana River. Specifically, an existing drainage facility located at the eastern portion of the Santa Ana River would be relocated slightly north of the existing location. Roadway widening activities would also install curb, gutter, and storm drain improvements along the affected segment of Orangewood Avenue.

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Following implementation of the proposed improvements to the local storm drainage system, stormwater would be collected and treated such that long- term operational impacts to water quality would be less than significant, and the level of impact would not increase from that identified in SEIR No. 339.

To determine the Project’s long-term operational impacts to the Santa Ana River, a scour analysis was prepared for the Proposed Project as part of the Basis of Design Report to ensure the design of the bridge structure improvements would account for any potential removal of material along the channel as a result of hydraulic forces; refer to Appendix D. Currently, there are a series of existing grade control structures in the Santa Ana River that currently protect the channel from long- term scour. However, based on the scour analysis, the existing bridge is susceptible to local scour.

The proposed bridge structure improvements would increase the water surface elevation within the limits of the Project resulting in an anticipated depth of total scour of 24.4 feet within the vicinity of the bridge.

With implementation of proposed scour countermeasures (e.g., modified bridge footings or placement of a permeable articulated concrete block [ACB] mat), the Project would protect the existing and proposed bridge foundations (i.e., bridge piers and pilings) from scour, improving the existing condition . As such, impacts related to scour would be less than significant in this regard.

b) Would the project substantially decrease groundwater suppli es or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 Appendix A.

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that impacts concerning substantially interfering with groundwater recharge would be less than significant since the Platinum Triangle is largely developed with urban uses and does not represent a s ubstantial groundwater recharging area. SEIR No. 339 noted that an additional groundwater well would be constructed within the PTMLUP area; however, this additional groundwater well would not substantially deplete groundwater supplies based on its location near the Orange County Water District (OCWD) Groundwater Basin.

SEIR No. 339 determined that conformance with existing regulatory requirements and standard conditions of approval would ensure the impacts related to groundwater supplies are less than significant.

Project‐Specific Analysis:

GROUNDWATER SUPPLIES

During construction, limited water supplies would be required for dust control and maintenance of construction vehicles and equipment. Based on the Projects scope and limited construction duration, it is not anticipated that construction would substantially deplete groundwater supplies. The Project does not propose the installation of landscaped medians or any other Project features which would require public water service during operation. The proposed water line extension is required to enhance the City of Orange’s water system and create the redundancy necessary for existing capacity requirements .

Thus, the Project would not impact groundwater supplies such that it would impede sustainable groundwater management of the basin, and the level of impact w ould not increase from that identified in SEIR No. 339. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated

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with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. However, given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR, one can anticipate that the level of impact to groundwater supplies would not increase from that identified in SEIR No. 339.

GROUNDWATER RECHARGE

As a roadway widening project, long- term operations of the Proposed Project would have the potential to interfere with groundwater recharge due to Orangewood Avenue ’s increase in impervious surfaces.

Although the Proposed Project would increase the amount of impervious surface area analyzed under SEIR No. 339, t he Project footprint would involve a segment of Orange wood Avenue which is already largely built -out with impervious surfaces. Nonetheless, the Project would be designed such that it minimizes grading and maintains the roadway’s existing drainage pattern to reduce potential impacts on groundwater recharge. The Project would implement design measures and BMPs to ensure that stormwater runoff volumes from the site do not increase from existing conditions; refer to Response 3.9 (a). The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. Accordingly, the Project would not impact groundwater recharge such that it would impede sustainable groundwater management of the basin, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

c) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 Appendix A.

1) Result in substantial erosion or siltation on- or off-site?

Previous Significance Determination:

The Initial Study for SEIR No. 339 noted that the runoff rates are expected to remain approximately the same as existing conditions, since PTMLUP buildout would not increase the runoff volume within the PTMLUP area. The Initial Study concluded that compli ance with the design requirements of the City and the OCFCD would ensure that runoff is properly conveyed and discharged as appropriate. Therefore, potential impacts associated with increases in runoff, including potential increased erosion or siltation, would be less than significant. Because these impacts were considered less than significant, they were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: Refer to Response 3.10 (a).

Significance Determination: No substantial increase in the level of impact from previous analysis.

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2) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that PTMLUP buildout would not significantly increase the amount of impervious surface within the Platinum Triangle and that runoff rates would remain approximately the same as existing conditions. The Initial Study determined that the Project would result in less than significant impacts concerning substantially altering the existing drainage pattern of the site or area following compliance with the design requirements of the City and the OCFCD. Because these impacts were considered less than significant, they were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: Refer to Response 3 .9 (c), above. As described in Section 2.0 , Project implementation would realign a segment of the Santa Ana River Trail along the western portion of the Santa Ana River, and reconstruct a segment of the trail along the eastern portion of the River to facilitate installation of new bridge support structures required for the bridge widening. The Proposed Project would not substantially alter the course of the Santa Ana River; the proposed improvements would be designed and constructed to maintain free flow beneath the bridge structure in conformance with OCFCD requirements. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. Therefore, impacts associated with the Proposed Project would be less than significant, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

3) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?

Pre
vious Significance Determination: The Initial Study for SEIR No. 339 concluded that impacts to water quality would be less than significant following compliance with the existing regulatory framework (i.e., local grading ordinance, State General Construction Permit, and County area-wi de MS4 Storm Water
Runoff Permit) would ensure that impacts are reduced to less than significant levels. The Initial Study concluded that impacts concerning r unoff water which would exceed the ca pacity o f existing or planned stor mwater drainage systems or provide substantial a dditional sources of pollutant r unoff would be less than significant. Because these impacts w ere considered less than significant, they were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: No substantial change from previous analysis. Refer to Responses 3.9 (a) and

3.9 (c) above. The Project would widen approximately a half-mile segment of Orangewood Avenue and thus would result in increased impervious surface area. The Project would demonstrate conformance with the State’s General Constructio n Permit, the Anaheim Municipal Code Chapter 17.04 (Grading, Excavations, Fills, Watercourses), and the City of Orange Grading Ordinance ( Orange Municipal Code Chapter 16.40). Conformance with these measures would ensure Project construction does not result in additional sources of polluted runoff. The Project would include the annexation of land adjacent to the Santa Ana River; however, no new development is proposed within the Santa Ana River reorganization

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area as part of this Project. Thus, Project implementation would not create or contribute runoff water which would exceed the existing or planned stormwater drainage systems, and the level of impact would not increase from that identified in SEIR No. 339.

Further, with the implementation of BMPs, and compliance with Federal, State, and local regulations the Project would not substantially degrade water quality. The Project would not result in substantial additional sources of polluted runoff, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

4) Impede or redirect flood flows?
Previous Significance Determination: Refer to Response 4.10 (c)(2) and 4.10 (c)(3).

Project‐Specific Analysis: No substantial change from previous analysis. Refer to Response 4.10 (c)(2) and 4.10 (c)(3) .

Significance Determination: No substantial increase in the level of impact from previous analysis.

d) In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 Appendix A.

Previous Significance Determination:

Flood Hazard

Th
e Initial Study for SEIR No. 339 concluded that the PTMLUP area is located within a Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) Special Flood Hazard Area designated as “Zone A99” and “X.” Based on these designation s, the Initial Study concluded that PTMLUP buildout would involve less than significant impacts concerning potential flooding. Because th ese impacts were considered less than significant, they were not further analyzed in SEIR No. 339. Nonetheless, SEIR No. 339 includes MM 3-1 to r
equire documentation that any structures must be at least 3 feet higher than the 100-ye
ar flood zone.

Tsunami

SEIR No. 339 did not evaluate the potential for PTMLUP buildout to be subject to tsunami-related impacts.

Seiche

The PTMLUP area does not support surface water bodies capable of causing a seiching event. Therefore, the Initial Study determined that PTMLUP buildout would not be subject to seiche-related i mpacts.

Because there were no impacts, they were not further analyzed in SEIR No. 339.

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Project‐Specific Analysis:

Flood Hazard

Flood hazard areas identified on the FIRM are labeled “Special Flood Hazard Area” (SFHA). FEMA identifies SFHAs as high-risk areas subject to inundation by one-percent-annual chance flood. 11 The one-
percent annual chance flood is also referred to as the base flood or 100 -year flood. Federal floodplain management regulations and mandatory flood insurance purchase requirements apply in these zones.

According to FEMA FIRM Panel 142, Map No. 06059C0142J (effective December 3, 2009), the Project Site is located in two FEMA Flood Zones: Flood Zone “X (Other Flood Areas)” and Flood Zone “A.”

Most of the affected roadway segment is located in Flood Zone “X,” which FEMA defines as an area of moderate flood hazard that has between a one percent and 0.2 percent chance of flooding within a given year. This is commonly described as the area subject to flooding between the 100 -year/base flood and 500-year flood. FEMA further identifies this area as p rotected from the one- percent annual chance or greater flood hazard by the Santa Ana River levee system. Thus, roadway improvements occurring within these areas would not place structures within a 100 -year flood hazard area and a less than significant impact would occur.

The Orangewood Avenue bridge widening and Santa Ana River Trail improvements are located within Flood Zone “A,” which FEMA defines as a reas subject to inundation by the one -percent annual chance flood event. Thus, these improvements would be sited in a 100-year floodplain as designated by FEMA.

Although these improvements would be installed within a 100 -year floodplain, the bridge support and Santa Ana River trail improvement would be designed such that impacts to the FEMA -designated Flood Zone are minimized and Santa Ana River flow is preserved; refer to Response 3.9 (d) above. These improvements would not reduce the functionality of the Santa Ana River’s existing levee system.

The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted location, type and intensity of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. Thus, impacts concerning the placement of structures within a 100 -year flood hazard area would be less than significant and the level of impact would not increase from that identified in SEIR No. 339.

No habitable aboveground structures are proposed under the Project and no new development would occur as a result of the Santa Ana River reorganization area; thus, the Project would not place housing within a 100-year flood hazard area as mapped on a Federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map. Thus, SEIR No. 339 MM 3 -1 is not applicable to the Proposed Project. No impact would occur in this regard, and the level of impact would not increase from that identified in SEIR No. 339.

11 Federal Emergency Management Agency Website, FEMA Zone Definitions , http://www.floodadvocate.com/fema-zone-
definitions/?gclid=CjwKEAjw4vzKBRCt9Zmg8f2blgESJADN5fDgTspDzPxBH5dp9mar2pUN_suNf1cjN8Rj8Vko6HTH HxoCzGz w_wcB, Accessed October 4, 2017.

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Tsunami

The Project Site is located nearly 12 miles inland of the Pacific Ocean. As a result, the Project is located at a sufficient distance so as not to be subject to tsunami impacts. No impact would occur in this regard.

Seiche

The Project is not located by a large, confined water body capable of causing a seiching event. Thus, there would be no impact associated with exposure of people or structures to seiche, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

e) Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 Appendix A.

Pre
vious Significance Determination: The Initial Study for SEIR No. 339 concluded that impacts to water quality would be less than significant following compliance with the existing regulatory framework (i.e., local grading ordinance, State General Construction Permit, and County area-wi de MS4 Storm Water
Runoff Permit) would ensure that impacts are reduced to less than significant levels. The Initial Study concluded that impacts concerning r unoff water which would exceed the ca pacity o f existing or planned stor mwater drainage systems or provide substantial a dditional sources of pollutant r unoff would be less than significant. Because these impacts w ere considered less than significant, they were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: Refer to Responses 3.9 (a) and 3.9 (c) above. The Project would widen approximately a half-mile segment of Orangewood Avenue and thus would result in increased impervious surface area. The Project would demonstrate conformance with the State’s General Construction Permit, as well as the Anaheim Municipal Code Chapter 17.04 (Grading, Excavations, Fills, Watercourses) and the City of Orange Gr ading Ordinance ( Orange Municipal Code Chapter 16.40).

Conformance with these measures would ensure Project construction does not result in additional sources of polluted runoff. As designed, the Project would not increase peak flow rates leaving the sit e, and discharge velocities would not be increased when compared to existing conditions. Thus, Project implementation would not create or contribute runoff water which would exceed the existing or planned stormwater drainage systems, and the level of impact would not increase from that identified in SEIR No. 339. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. W ith the im plementation of BMPs, and compliance with Federal, State, and local regulations the Project would not substantially degrade water quality. The Project would not result in substantial additional sources of polluted runoff, and the level of impact would not increase from that identified in SEIR No. 339.

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Significance Determination: No substantial increase in the level of impact from previous analysis.

3.10.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

Refer to the Mitigation Measures from SEIR No. 339 below, which are based on adopted Mitigation Measures from SEIR No. 332.

Mitigation Measures from SEIR No. 339

SEIR No. 339 includes measures to reduce potential impacts associated the development and infrastructure improvements within the Platinum Triangle. The following measure from SEIR No. 339 is applicable to the Proposed Project.
12 Any modifications to the original measure is shown in strikethrough for deleted text and new, inserted text is underlined.

MM 3-2 P rior to the initiation of grading activities, for projects greater than one acre, coverage for the project must be obtained by electronically submitting permit registration documents to the State or obtaining coverage via current general construction permit prescribed method by the property owner/developer City pursuant to State and Fe deral National Pollution Discharge Elimination System (NPDES) re quirements. As part of the Notice of Intent, a Surface Water Pollution Prevention Plan ( SWPPP) shall be prepared. The property owner/developer City shall also prepare and submit to the Development Services Division of the Public Works Department, a Water Quality Management Plan (WQMP) in accordance with the City’s municipal NPDES requirements and Chapter 7 of the Orange County Drainage Area Management Plan. The WQMP must be approved prior to issuance of grading permit.

The SWPPP, in conjunction with the WQMP, will describe the structural and nonstructural best management practices (BMPs) that will be implemented du ring construction (short- term
) within the Project Area as well as BMPs for long-term o peration of the Project Area
that address potential impacts to surface waters.

12 Mitigation measure numbering corresponds to Platinum Triangle Master Land Use Plan Appendix C, Updated and Modified Mitigation Monitoring Program Number 106C.

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3.11 LAND USE AND PLANNING

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Physically divide an established community? 
b. Cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?


a) Would the project physically divide an established community?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that no physical division of an established community would result from i mplementation of the PTMLUP and no mitigation was required. Because there were no impacts, this topic was not further analyzed in SEIR No. 339.

Project‐Specific Analysis: The Project Site involves an approximately half- mile long segment of the existing roadway (Orangewood Avenue) generally east of Rampart Street and ending just east of Eckhoff Street, consists of improved roadway right -of-way, pedestrian and bicycle facilities, and infrastructure improvements. The Project is surrounded by channelized portions of the Santa Ana River, and developed areas consisting of SR-57, commercial, and residential land uses.

Project implementation would not divide an established community. Further, the proposed Orangewood Avenue roadway widening is anticipated to improve area circulation opportunities along the affected segment to further advance community connectivity. Additionally, the proposed reorganization of municipal jurisdiction along the Santa Ana River would not result in any development that could physically divide an established community. As such, no impacts concer ning the division of an established community would occur, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

b) Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or miti gating an environmental effect?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 on page 5.4-5.

Pre
vious Significance Determination: SEIR No. 339 concluded that PTMLUP buildout would result in less than significant i mpacts to C ity and SCAG land use plans, policies, and regulations following conformance with existing regulatory requirements . However, S EIR No. 339 concluded that the PTMLUP would be inconsistent with the Anaheim General Plan’s Public Services and Facilities Element Goal 8.1, as high-rise re
sidential towers ( A-Tow
n Metro pr oject) could potentially inte rfere with t he

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Southern California Gas Company’s microwave tower’s telecommunications function. I mpacts in this regard w ere determined to remain significant and unavoidable, and a Statement of Overriding Considerations was adopted by the City Council when SEIR No. 339 was certified.

Fo
llowing SEIR No. 339 certification, SEIR No. 339 Addendum No. 4 evaluated the amended A-T own Metro
Project which included a Development Agreement amendment, Anaheim General Plan amendment, and PTMLUP amendment. Addendum 4 found that A -Tow
n Metro Project would be consistent with all
applicable goals and policies of the General Plan’s Land Use, Economic Development, and Community Design Elements. Additionally, the A ddendum 4 concluded that the A-T own Metro included a
provision to limit the maximum height of buildings; however, impacts would continue to be significant and unavoidable and no change to the level of significance from that of SEIR No. 339 would occur.

Project‐Specific Analysis: As a roadway segment, the Project Site (Orangewood Avenue) does not have a City of Anaheim or City of Orange land use designation. However, in addition to roadway improvements along Orangewood Avenue, the Proposed Project would reorganize land within the Project area through a municipal bounda ry adjustment within the Project limits to annex land outside of the City limits (currently in the City of Orange) into the City of Anaheim, incorporating properties within the City’s sphere of influence and expanding the boundaries of Platinum Triangle; r efer to Exhibit 2-5. Table 2-1 shows the existing and proposed land use designations and zoning for the areas proposed for annexation.

Refer also to Exhibit s 2-6 through Exhibit 2-9 for proposed land use designations and zoning within the reorganizational area, respectively. In addition to LAFCO approval, t he changes to the municipal boundaries and proposed land use and zoning in the reorganizational area would require amendments to the General Plan Land Use Element, Zoning Map, and Platinum Triangle Master Land Use Plan; refer to Exhibit 2-10. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

Area 1A and Area 1

As shown on Exhibit 2-5, Area 1A and Area 1 are located south of Orangewood Avenue and bound by North Net Training Center (2400 Orangewood Ave nue) to the west and the Santa Ana River Trail to the east. The proposed reorganization would realign a sliver of the North Net Training Center property to allow the entire parcel to be loc ated within the Anaheim city limits and would continue to provide operational use for the North Net Training Center. The Project proposes to amend the General Plan Land Use Element to change the land use designation for Area 1A and Area 1 from Open Space t o Mixed-Use Urban Core (refer to Exhibits 2-6 and 2-7). In addition, the Project would amend the Zoning Map to reclassify Area 1A and Area 1 to the “PR” Public Recreational Zone and Sub Area B of the Orangewood District of the PTMU Overlay Zone. The Project would also amend the PTMLUP to include Area 1A and 1 in Sub Area B of the Orangewood District . The proposed amendments would be consistent with the existing North Net Training Center.

The Mixed-Use Urban Core designation is intended for a m ix of uses, including residential, commercial, services, hotel, and professional office uses in a high -quality, pedestrian-friendly environment. The maximum density for the residential component of mixed -use development is up to 100 dwelling units per acre. The maximum floor area ratio for the non-residential component of mixed-use development is

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The intent of the PTMU Overlay Zone is to provide opportunities for well-designed development projects that combine residential with non- residential uses. Non-residential uses may office, retail, business services, personal services, public spaces and uses, and other community amenities within the portions of the Platinum Triangle designated with the Mixed-Use, Office High, and Office Low designations in the Anaheim General Plan.

The proposed amendments would not increase the maximum permitted development above the 321 dwelling units previously analyzed in the SEIR No. 339 for Sub Area B of the Orangewood District of the PTMU Overlay Zone. In the event the subject properties, including the existing North Net Training Center, are considered for future development, the maximum development intensity of 321 dwelling units would apply to all of Sub Area B. However, this is not anticipated in the near futu re at this time. As such, the proposed amendments to the General Plan, Zoning Map and PTMLUP for Area 1A and Area 1 would result in a less than significant impact concerning conflicts with an applicable land use plan, policy, or regulation, and the level of impact would not increase from that identified in SEIR No. 339.

Area 2A Stadium Sliver

The proposed reorganization does not include a sliver of the Angel Stadium property (Area 2A) as depicted in Exhibit 2-5. The Local Agency Formation Commission of Orange County (LAFCO) adopted Resolution No. RO 21-04 approving the “Santa Ana River Reorganization – Area 2A” on October 13, 2021. Area 2A continues to provide parking for Angel Stadium and no changes are proposed to Area 2A’s land use designation or zoning, which were amended in 2007 in anticipation of this reorganization with the City of Orange. The Stadium District Sub- Area A Project Sustainable Communities Environmental Assessment (Development Project No. 2020-00127), prepared by LSA and dated July 2020, analyzed development of this property consistent with its General Plan designation and zoning.

Area 2

As shown on Exhibit 2 -5, Area 2 is located north of Orangewood Avenue and consists of a regional bike trail and landscaping. The City is currently studying the potential to purchase Area 2 from the OCFCD for the development of a park as part of a future, separate and independent project . A General Plan Amendment and Zoning Map Amendment would be required to change Area 2 land use designation from Open Space to Parks and zoning to the PR Zone; refer to Exhibits 2-6 through 2-9. The Parks designation allows for active and passive recreational uses such as parks, trails, athletic fields, interpretive centers , and golf courses. The Parks land designation permits a maximum floor area ratio of 0.10. The PR zone implements the Parks land use designation. The intent of the PR zone is to establish for the benefit of the health, safety, and general welfare of the citizens of Anaheim and its visitors, a zone to preserve, regulate, and control the orderly use and enjoyment of City -owned properties and facilities and adjacent private property. Properties within the purview of the PR zone include: (a) City-owned properties, whether the same is exclusively occupied by the City or is used by others on the basis of some agreement with or concession by the City; and (b) adjacent private properties, whose uses and development have an impact on the use and enjoyment of City -owned properties and facilities. As such, the proposed amendments would not conflict with an applicable land use plan, policy, or regulation, and the less than significant level of impact would not increase from that identified in SEIR No. 339.

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Area 3 and Remaining Area

The General Plan Circulation Element would continue to designate Area 3, Orangewood Avenue, as a Primary Arterial. The General Plan Land Use Element would continue to designate the remaining area north and south of Orangewood Avenue, between the Proposed City Boundary and Areas 1, 1A, 2 and 2A, for Open Space land use. The Open Space land use designation applies to properties intended to remain in natural open space; utility easements that will provide recreational and trail acce ss to Anaheim’s residents; heavily landscaped freeway remnant parcels, and land areas surrounding major water features.

The Proposed Project would apply the OS Zone to this area. The OS Zone is the implementing Zone for the General Plan Open Space land us e designation and permits a maximum floor area ratio of 0.10.

Currently, the City of Anaheim Zoning Map does not include this area within any Zone.

Significance Determination: No substantial increase in the level of impact from previous analysis.

3.11.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

SEIR No. 332 does not include mitigation measures for land use and planning.

Mitigation Measures from SEIR No. 339

SEIR No. 339 mitigation measures are not applicable to the Proposed Project.

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3.12 MINERAL RESOURCES

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Result in the loss of availability of a known mineral resource that would be of value to the region and the
residents of the state?

b. Result in the loss of availability of a locally -important mineral resource recovery site delineated on a local
general plan, specific plan or other land use plan?


a) Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the PTMLUP area does not include mineral resources and the PTMLUP area; thus, PTMLUP implementation would not result in the loss of the availability of mineral resources that would be of regional value. Because there were no impacts, these resources were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: The Anaheim General Plan Green Element states that parts of East Anaheim, Anaheim Canyon, and the Hill and Canyon Areas are i ncluded in Mineral Resources Zone (M RZ) MRZ-

2. Th
e Orange General Plan Natural Resources Element designates the sand and gravel resources (aggregate) contained in and along the Santa Ana River as mineral resources. The Project’s proposed improvements along the Santa Ana River Trail would occur within an area designated by th e Orange General Plan as containing mineral resources . However, these improvements would be limited to realigning a small segment of the Santa Ana River Trail and relocating an existing drainage facility located at the eastern portion of the Santa Ana River to accommodate the proposed bridge widening. Five existing bents situated along the River bottom would be lengthened for the widening and scour improvements are proposed to protect the proposed bridge structure . The nature of these improvements would not change the availability of aggregate resources contained in and along the Santa Ana River. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the location and the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. The City of Orange evaluates development within areas containing aggregates or other deposits which are significant to the regional economy to ensure adequate mitigation or preservation of these areas for future aggregate mining opportunities. Thus, impacts concerning the loss of availability of a known mineral resource that would be of value to the region and the residents of the State would be less than significant, and the level of increase would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

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b) Would the project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that the PTMLUP area does not contain any mineral resources and that PTMLUP implementation would not result in the loss of the availability of mineral resources that would be of regional value. Because th ere were no impacts, these resources were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: As discussed in Response 3.11 (a), above, the Project would not result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan, and the level of increase would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

3.12.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

SEIR No. 332 does not include mitigation measures for mineral resources.

Mitigation Measures from SEIR No. 339

SEIR No. 332 does not include mitigation measures for mineral resources.

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3.13 NOISE

Would the project result in:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?

b. Generation of excessive groundborne vibration or
groundborne noise levels? 
c. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public
airport or public use airport, would the project expose people residing or working in the project area to
excessive noise levels?


a) Would the project result in generation of substantial temporary or permanent increases in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 page 5.5-19.

Pre
vious Significance Determination: SEIR No. 339 determined that PTMLUP implementation could expose persons to, or generate, noise levels in excess of standards established in the Anaheim General Plan and Anaheim Noise Ordinance ( Anaheim Municipal Code Chapter 6.70, Sound Pressure Levels) .

Specifically, SEIR No. 339 concluded that PTMLUP buildout would result in a significant increase in noise generated by vehicular traffic along Gene Autry Way from I-5 to State College Boulevard and on State College Boulevard from Orangewood Avenue to Gene Autry Drive. SEIR No. 339 also determined that PTMLUP buildout would allow for noise-sensitive residential units which may be exposed to mobile and stationary noise levels that exceed State and/or City standards and that building façades that are exposed to noise levels that exceed 69 A-wei
ghted decibels (dBA) would require architectural improvements to a chieve the required 45 dBA community noise equivalent level (CNEL) interior noise level limits.

Des
pite implementation of SEIR No. 339 MMs 5-1 t
hrough 5-5
and MM 5-7 t
hrough 5-10,
impacts
concerning exposure to mobile- and st ationary-sou rce noise and vibration were determined to remain significant and unavoidable, and a Statement of O verriding Considerations was adopted by the City Council when SEIR No. 339 was certified.

Project‐Specific Analysis: It is difficult to specify noise levels that are generally acceptable to everyone; what is annoying to one person may be unnoticed by another. Standards may be based on documented complaints in response to documented noise levels, or based on studies of the ability of people to sleep, talk, or work under various noise conditions; however, all such studies recognize that individual responses vary considerably. Standards usually address the needs of the majority of the general population.

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SH
ORT-T

ERM CONSTRUCTION IMPACTS

Construction activities generally are temporary and have a short duration, resulting in periodic increases in the ambient noise environment. Construction of the Proposed Project would occur over approximately 12 months and would include demolition, grading, paving, and roadway construction. Groundborne noise and other types of construction -related noise impacts typically occur during the initial site preparation. This phase of construction has the potential to create the highest levels of noise; however, it is generally the shortest of all construction phases. Typical noise levels generated by construction equipment are shown in Table 3.13-1, Maximum Noise Levels Generated by Construction Equipment .

Operating cycles for these types of construction equipment may involve one or two minutes of full power operation followed by three to four minutes at lower power settings. Other primary sources of acoustical disturbance would be due to random incidents, which would last less than one minute (such as dropping large pieces of equipment or the hydraulic movement of machinery lifts).

Table 3.13-1
Maximum Noise Levels Generated by Construction Equipment

Type of Equipment Acoustical Use Factor Lmax at 50 Feet (Dba) Concrete Saw 20 90
Concrete Mixer Truck 40 79
Backhoe 40 78
Dozer 40 82
Excavator 40 81
Forklift 40 78
Paver 50 77
Roller 20 80
Tractor 40 84
Water Truck 40 80
Grader 40 85
General Industrial Equipment 50 85
Jackhammer 20 89
Note:

1. Acoustical Use Factor (percent): Estimates the fraction of time each piece of construction equipment is operating at full power (i.e., its loudest condition) during a construction operation.

Source: Federal Highway Administration, Roadway Construction Noise Model (FHWA-HEP-05-054), January 2006.

The closest sensitive uses in the Project area include a surgical center (Orangewood Surgical Center) located approximately 70 feet to the northeast, and residential uses located approximately 20 feet to the southeast. These sensitive uses may be exposed to elevated noise levels during Project construction.

However, as the Project involves the widening of a roadway, construction noise would not be concentrated in one location for extended periods of time, since construction equipment would move in a linear fashion along the Project area. The remainder of the Project Site is surrounded by commercial, institutional, and industrial uses.

Construction noise is regulated by the Anaheim Municipal Code and Orange Municipal Code . In conformance with Anaheim Municipal Code , construction noise sources are exempted from the City’s

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Noise Ordinance standards between the hours of 7:00 AM and 7:00 PM. Similarly, the Orange Municipal Code exempts construction noise sources from the City’s Noise Ordinance standards between the hours of 7:00 AM to 8:00 PM on weekdays. The Proposed Project would be subject to compliance with the construction time limitations identified in Anaheim Municipal Code Section 6.70.010 and Orange Municipal Co de Section 8.24.070. Following adherence to the Municipal Code construction time regulations as well as implementation o f SEIR No. 339 MMs 5-7 t hrough 5-10, s
hort-term
construction
noise impacts would not result in new or significantly increased impacts as compared to the level identified in SEIR No. 339.

LO
NG-TER

M OPERATIONAL IMPACTS

Pr
oject implementation would not introduce a new noise-generating source. As described above, Project implementation would accommodate existing and future traffic levels associated with buildout of the PTMLUP. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future d evelopment of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the location and the permitted type and intensity of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

Therefore, long-term noise levels would be consistent with those analyzed as part of SEIR No. 339, as the Project would not generate additional traffic beyond what was analyzed in SEIR No. 339 and its addenda; refer to Section 3.17. Generally, a 3 dBA change in the existing ambient noise level is required to instigate a perceivable/noticeable difference in the ambient noise environment . According to the Caltrans Technical Noise Supplement to the Traffic Noise Analysis Protocol (2013), a doubling of traffic on a roadway is required to result in an increase of 3 dB (a barely perceptible increase). The proposed Orangewood Avenue widening would not accommodate a doubling of existing traffic, and thus, would not result in a perceptible increase in traffic noise levels. No new long-t erm noise impacts would occur as a result of
Project operations. Following adherence to SEIR No. 339 MM 5 -7 through MM 5 -10, long-term noise impacts would not result in new or significantly increased impacts as compared to the level identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

b) Would the project re sult in generat ion of excessive groundborne vibration or groundborne noise levels?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 pages 5.5-29 and

5.5-31.

Pre
vious Significance Determination: SEIR No. 339 concluded that PTMLUP implementation had the potential to result in exposure o f persons to or generation of excessive gr oundborne v ibration or groundborne noise levels. Specifically, SEIR No. 339 found that PTMLUP construction activities would generate substantial levels of groundborne vibration and groundborne noise in the vicinity of vibration- se
nsitive land uses and that vibratio n-se
nsitive receptors could be exposed to substantial levels of groundborne vibration and groundborne noise in the vicinity of th e Amtrak/M etrolink li ne. Despite implementation of SEIR No. 339 mitigation measures, impacts related to generation of substantial levels

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of g roundborne vibration and groundborne noise in the vicinity of vibration-se nsitive land uses were determined to remain significant and unavoidable, and a Statement of Overriding Considerations was adopted by the City Council when SEIR No. 339 was certified.

Project‐Specific Analysis:

SH
ORT-T

ERM CONSTRUCTION IMPACTS

Pr
oject construction would have the potential to result in varying degrees of temporary groundborne vibration, depending on the specific construction equipment used and the operations involved. Vibration generated by construction equipment spreads through the ground and diminishes in magnitude with increases in distance. Construction vibration could represent a source of annoyance to the identified sensitive receptors along the affected segment of Orangewood Avenue. Construction activities would occur as close as 100 feet from the Orangewood Surgical C enter and 300 feet from the closest sensitive receptors. Based on reference vibration levels analyzed in SEIR No. 339, vibration levels from typical construction equipment would diminish substantially at 100 feet and would not exceed thresholds for structural damage or levels that are strongly perceptible as identified by the Federal Transit Administration (FTA) and Caltrans. Pile driving would occur for the modifications to the bridge structure over the Santa Ana River. However, these activities would occur more than 500 feet from the nearest structure. At this distance, construction vibration levels would diminish below the distinctly perceptible level. As such, short
-term
construction vibration would not result in new or significantly increased impacts as compared to the level identified in SEIR No. 339. No mitigation would be required.

LO
NG-TER

M OPERATIONAL IMPACTS

As a roadway widening and annexation project, operations would not generate a new source of groundborne vibration. As indicated in Section 3. 17, the proposed improvements would not increase vehicular capacity of Orangewood Avenue. Impacts would be les s than significant, and long- term operational impacts would not result in new or significantly increased impacts as compared to the level identified in SEIR No. 339.

In addition, the proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

c) Would the project be located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 page 5.5-34.

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Previous Significance Determination: As discussed in Section 3.9, Hazards and Hazardous Materials, SEIR No. 339 identified three existing locations within the vicinity of the Platinum Triangle that support helicopter take offs/landings. SEIR No. 339 also disclosed that future heliports/helipads could be constructed in the Platinum Triangle area atop new high-rise s tructures for fire and emergency response
use. SEIR No. 339 determined that despite the potential for noise-sen sitive uses to be placed in proximity
to heliports/helipads and a reas of helicopter activity, use of these heliports would be infrequent.

Therefore, SEIR No. 339 found impacts associated with private airstrip/heliport/helipad noise to be less than significant.

SEIR No. 339 determined that the Platinum Triangle area is not located within an airport land use plan or within two miles of a pu blic airport. T he nearest public airports to the Platinum Triangle Area include John Wayne Airport, located approximately eight miles to the south, and Fullerton Municipal Airport, located approximately eight miles to the northwest. Therefore, SEIR No. 339 found that no impacts associated with public airport noise would occur.

Project‐Specific Analysis: The western extent of the Project Site is adjacent to two City of Anaheim heliports which could potentially pose helicopter safety hazards: Angels Stadium and the North Net Fire Training Center. In addition, the City of Orange includes three heliports: UC Irvine Medical Center; Children’s Hospital of Orange County; and the SCE Serrano Substation; refer to Response 3.8 (f).

Roadway construction activities would involve temporary impacts to ambient noise. However, based on the degree of changes identified in Section 2.0, Project implementation would not expose people residing or working in the Project area to excessive noise impacts beyond what was already analyzed within SEIR No. 339. Project operations would not introduce a new noise generating source. For this reason, impacts concerning helicopter noise levels would not increase from that identified in SEIR No. 339, and impacts would be less than significant.

The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganizatio n reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

As stated above, the Platinum Triangle (including the Project Site) is not located within an airport land use plan or within two miles of a public airport. Therefore, no impacts associated with public airport noise would occur, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

3.13.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

Refer to the Mitigation Measures from SEIR No. 339 below, which are based on adopted Mitigation Measures from SEIR No. 332.

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Mitigation Measures from SEIR No. 339

SEIR No. 3 39 includes measures to reduce potential impacts associated the development and infrastructure improvements within the Platinum Triangle. The following measures from SEIR No. 339 are applicable to the Proposed Project. 13 Any modifications to the original measures are shown in strikethrough for deleted text and new, inserted text is underlined.

MM 5-7 O ngoing during grading, demolition, and construction, the property owner/developer City shall be responsible for requiring contractors to implement the following measures to limit construction-rel
ated noise:

a. Noise generated by construction, shall be limited by the property owner/developer City to 60 dBA along the property boundaries, before 7:00 AM and after 7:00 PM, as governed by Chapter 6.7, Sound Pressure Levels, of the Anaheim Municipal Code.

b. Limit the hours of operation of equipment that pr oduces noise levels noticeably above general construction noise levels to the hours of 10:00 AM to 4:00 PM. c. Al
l internal combustion engines on all of the construction equipment shall be properly outfitted with well-main
tained muffler systems.

MM 5-8 O ngoing du ring construction activities, the property owner/developer City s hall be responsible for requiring project contractors to properly maintain and tune all construction equipment to minimize noise emissions.

MM 5-9 O ngoing du ring construction activities, the property owner/developer City s hall be responsible for requiring project contractors to locate all stationary noise sources (e .g., generators, compressors, staging areas) as far from occupied noise-sen sitive receptors as is
feasible.

MM 5-10 On going during construction activities, material delivery, soil haul trucks, and e quipment servicing shall also be restricted to the hours set forth in the City of Anaheim Municipal Code, Section 6.70.

13 Mitigation measure numbering corresponds to Platinum Triangle Master Land Use Plan Appendix C, Updated and Modified Mitigation Monitoring Program Number 106C.

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3.14 POPULATION AND HOUSING

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Induce substantial unplanned population growth in an area, either directly (for example, by proposing new
homes and businesses) or indirectly (for example,
through extension of roads or other infrastructure)?

b. Displace substantial numbers of existing people or
housing, necessitating the construction of replacement
housing elsewhere?


a) Would the project induce substantial unplanned population growth in an area, either directly (f or example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 on page 5.6-13.

Previous Significance Determination: SEIR No. 339 concluded that the residential and non- residential development accommodated through PTMLUP implementation would di rectly and indirectly induce population growth . Although PTMLUP buildout would result in indirect and direct population growth, the SEIR No. 339 concluded that it would be consistent with SCAG’s regional growth management policies since its implementation would result in a more balanced jobs/housing ratio when compared to existing conditions. No impacts were identified and no mitigation was required.

Project‐Specific Analysis: As a roadway improvement and annexation project, the Proposed Project would not directly induce substantial population growth in an area through the introduction of new residential housing or businesses, as neither of these uses would occur with Project implementation. The Project does not involve roadway extensions, and would be limited to the introduction of a new westbound travel lane ( and associated improvements) to accommodate existing and anticipated vehicular traffic associated with buildout of the PTMLUP. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. As such, the Project is not anticipated to induce substantial unplanned population growth in the area, either indirectly or directly. A less than significant impact would occur in this regard , and the level of impact would not increase from that identified in SEIR No. 339.

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b) Would the project displace subs tantial nu mbers of exis ting people or housing, necessitating the construction of replacement housing elsewhere?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 Appendix A.

Previous Significance Determ ination: The Initial Study for SEIR No. 339 determined that PTMLUP implementation would not displace people or residential development. As such, impacts in this regard were not further analyzed in SEIR No 339.

Project‐Specific Analysis: No housing units would be displaced as a result of Project implementation.

Existing residential land uses are present within the Project vicinity. However, all Project improvements would occur along an existing segment of Orangewood Avenue, OCFCD-managed segments of the Santa Ana River Trail, and Santa Ana River reorganization area, which is currently vacant land . The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. A s such, Project implementation would not displace any existing housing units or people requiring the construction of additional replacement housing units elsewhere and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

3.14.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

SEIR No. 332 does not include mitigation measures for population and housing.

Mitigation Measures from SEIR No. 339

SEIR No. 339 does not include mitigation measures for population and housing.

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3.15 PUBLIC SERVICES

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Would the project result in substantial adverse physical impacts associated with the provision of new or
physically altered governmental facilities, need for new or physically altered governmental facilities, the
construction of which could cause significant
environmental impacts, in order to maintain acceptable
service ratios, response times or other performance
objectives for any of the public services:

1) Fire protection? 
2) Police protection? 
3) Schools? 
4) Parks? 
5) Other public facilities? 

a. Would the project result in substantial adverse physic al impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities , the cons truction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:

1) Fire Protection?

Previous Significance Determination: SEIR No. 339 determined that Platinum Triangle buildout would necessitate additional fire facilities, delay the AFD’s response time for first engine response, and increase demand for other operational sections of the AFD. To mitigate these impacts to fire protection services, SEIR No. 339 concluded that increases in property tax revenues generated by PTMLUP buildout would be used for additional AFD staffing needs. Furthermore, the Public Safety Impact Fee would be collected at the time o f issuance of building permits for projects in the Platinum Triangle, providing funds for the construction of new fire facilities. SEIR No. 339 found impacts associated with fire protection facilities to be less than significant with the incorporation of SEIR No. 339 MM 7 -1 an d MM 7-2.

Project‐Specific Analysis: The Proposed Project would not result in the construction of aboveground structures which are at risk to fire and would not directly or indirectly induce significant population growth; refer to Response 3.13 (a). As a roadway widening and annexation project, the Project would not result in the need for additional new or physically altered AFD or City of Orange Fire Department (OFD) fire protection facilities. In fact, Project implementation would result in a long-term benefit to fire protection services, as it would improve traffic flow along Orangewood Avenue through its addition of a new westbound travel lane, thereby improving emergency response times. As a roadway infrastructure and annexation project, SEIR No. 339 MM 7-1 and 7-2 are not applicable to th e Proposed Project since the Project does not require fire sprinklers or re quire the payment of Public Safety Impact Fees. No impacts would occur, and the level of impact would not increase from that identified in SEIR No. 339.

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Significance Determination: No substantial increase in the level of impact from previous analysis.

2) Police Prot ection?

Previous Significance Determination: SEIR No. 339 concluded that PTMLUP buildout would require an increase in police facilities and staffing at the Anaheim Police Department ( APD). To mitigate these impacts to police protection services, SEIR No. 339 concluded that increases in property tax revenues generated by PTMLUP buildout would be us ed to for additional APD staffing needs. Furthermore, the Public Safety Impact Fee would be collected at the time of issuance of building permits for projects in the Platinum Triangle, providing funds for the construction of new police protection facilities. The SEIR found impacts associated with police protection facilities to be less than significant with the incorporation of SEIR No. 339 MM 7-3 throu
gh MM 7-7.

Project‐Specific Analysis: The Proposed Project would not directly or indirectly induce significant population growth; refer to Response 3.13 (a) above. As a roadway widening and annexation project, the Project would not result in the need for additional new or physically altered APD or Orange Police Department (OPD) police protection facilities. In fact, Project implementation would result in a long-term benefit to police protection services, as it would improve traffic flow along Orangewood Avenue through its addition of a new westbound travel lane, thereby improving emergency response times. As a roadway infrastructure and annexation project, SEIR No. 339 MM 7 -3 through 7 -7 are not a pplicable to the Proposed Project , since the Project does not r equire safety measures for crime pr evention, does not include parking lots or parking structures, and does not require the payment of Public Safety Impact Fees.

No impacts would occur, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

3) Schools?

Previous Significance Determination: SEIR No. 339 concluded that residential development within the Platinum Triangle would generate additional students requiring school services in the Anaheim City School District and Anaheim Un ion High School District. T o mitigate impacts to school services, SEIR No. 339 concluded that developer payment of school fees levied by Anaheim City School District and Anaheim Union Hi gh School District would reduce potential school-rel ated impacts to a less than
significant level. SEIR No. 339 found impacts associated with schools to be less than significant with the incorporation of SEIR No. 339 MM 7-8 a
nd MM 7-9.

Project‐Specific Analysis: As a roadway infrastructure and annexation project, the Proposed Project would not directly or indirectly induce significant population growth; refer to Response 3.13 (a). Thus, the Project would not generate school -aged students that would create a deman d on local schools for educational services. As a roadway infrastructure and annexation project, SEIR No. 339 MM 7-8 and 7-9 are not applicable to the Proposed Project since the Project would not i mpact the school districts. No impacts would occur, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

4) Parks?

Previous Significance Determination: SEIR No. 339 concluded that PTMLUP buildout would generate additional residents which would increase local demand for parks and recreational facilities and could

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exacerbate existing overuse of parks in the City. However, t he SEIR conc luded that compliance with Anaheim Municipal Code Section 18.20.110.010, which establishes requirements for recreational space within the PTMU Overlay Zone, would ensure that recreational space wo uld increase proportional to population growth in the Platinum Triangle. SEIR No. 339 concluded that impacts associated with parks and recreational facilities would be les s than significant following conformance with existing a pplicable regulations and SEIR No. 339 MM 8-1 t
hrough MM 8-3.

Project‐Specific Analysis: Refer the responses above. As a roadway widening and annexation project, no new residents would be generated that would impact or create a need for additional local parks or other public facilities. Further, the Project would not increase the capacity of the road such that an indirect population growth would result. SEIR No. 339 MM 8- 1 through MM 8 -3 are not applicable to the Proposed Project because the Project would not negatively affect parks or recreational facilities. No impact would occur in this regard, and the level of impact would not increase from that identified in SEIR No. 339. In fact, the Project would amend the General Plan, Zoning Map and PTMLUP to designate additional land within the Platinum Triangle for future Park use. T he future development of a P ark use would be subject to analysis pursuant to CEQA. However, given that development of the area proposed for Park use would be similar in intensity to its current designation as Open Space, one can anticipate that the level of impact would not increase significant from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

5) Other public facilities?

Previous Significance Determination: SEIR No. 339 determined that PTMLUP buildout would generate additional residents which would increase demands for other public facilities in the a rea, including libraries. SE IR No. 339 found impacts associated with public facilities such as libraries to be less than significant with incorporation of SEIR No. 339 MM 7-10
, which requires payment of development impact
fees which would pay for additional library materials and services needed to serve the PTMLUP area.

Project‐Specific Analysis: Refer to the responses above. As a roadway widening and annexation project, no new residents would be generated that would impact or create a need for other public facilities, such as libraries. Further, the Project would not increase the capacity of the road such that an indirect population growth would r esult. SEIR No. 339 MM 7- 10 is not applic able to the Proposed Project because the Project would not affect library services. No impact would occur in this regard, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

3.15.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

SEIR No. 332 does not include mitigation measures for public services.

Mit
igation Measures from SEIR No. 339

SEIR No. 339 mitigation measures are not applicable to the Proposed Project.

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3.16 RECREATION

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Would the project increase the use of existing
neighborhood and regional parks or other recreational
facilities such that substantial physical deterioration of the facility would occur or be accelerated?

b. Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the
environment?


a) Would the project inc rease the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deter ioration of the facility would occur or be accelerated?

Pr
evious Significance Determination: SEIR No. 339 determined that PTMLUP buildout would generate additional residents which would increase local demand for parks and other recreational amenities and could exacerbate existing overuse of parks in the City. However, SEIR No. 339 concluded that compliance with Anaheim Municipal C ode Section 18.20.110.010, which establishes requirements fo r recreational space within the PTMU Overlay Zone, would ensure that recreational space would increase proportional to population growth in the Platinum Triangle. SEIR No. 339 determined that PTMLUP buildout would result in less than significant impa cts to parks and recreational facilities following co mpliance with applicable regulations and the incorporation of SEIR No. 339 MM 8-1 t hrough MM 8-3.

Project‐Specific Analysis: Refer to Response 3. 15 (a)(4). As a roadway widening and annexation project, Project implementation would not involve substantial population growth or increased demand for or use of existing neighborhood or regional parks or other recreational facilities. The Project does not propose the construction or expansion of recreational facilities. SEIR No. 339 MM 8- 1 through MM 8-3 are not applic able to the Proposed Project because the Project would not negatively affect parks or recreational facilities. No impacts concerning parks and recreational facilities would occur in this regard, and the level of impact would not increase from that identified in SEIR No. 339. In fact, the Project would amend the General Plan, Zoning Map and PTMLUP to designate additional land within the Platinum Triangle for future Park use. The future development of a park would be subject to analysis pursuant to CEQA. However, given that development of the area proposed for Park use would be similar in intensity to its current designation as Open Space, one can anticipate that the level of impact would not increase significant from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

b) Does the project include recreat ional facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment?

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Final | March 2022 3-86 Environmental Analysis
Previous Significance Determination: SEIR No. 339 determined that PTMLUP buildout would generate additional residents which would increase local demand for parks and other recreational amenities and could exacerbate existing overuse of parks in the City. However, the SEIR concluded that compliance with Anaheim Municipal Code Section 18.20.110.010, which establishes requirements for recreational space within the PTMU Overlay Zone, would ensu re that r ecreational space would increase proportional to population growth in the Platinum Triangle. SEIR No. 339 determined that PTMLUP buildout would result in less than significant i mpacts to parks and recreational facilities following compliance with applicable regulations and incorporation of SEIR No. 339 MM 8-1 t
hrough MM 8-3.

Project‐Specific Analysis: Refer to Response 3.1 5 (a). The Proposed Project would include the construction of a bicycle lane along the widened Orangewood Avenue and realignment of the Santa Ana River Trail. Additionally, the Proposed Project would install n ew retaining walls under the Orangewood Avenue bridge structure to maintain the existing trail. The Project would also include the annexation of land near the Santa Ana River; however, no new development is proposed within the Santa Ana River reorganization area as part of this Project. The Proposed P roject’s potential environmental impacts associated with the construction of the abovementioned recreational facilities are analyzed in this Addendum. Construction of the bicycle lane and the proposed trail improvements would be subject to compliance with all applicable local, State, and Federal laws, ordinances, and regulations, as well as the specific mitigation measures applicable to the Proposed Project identified within this Addendum .

Compliance with the relevant laws, ordinances, and regulations, as well as the specified mitigation measures, would ensure the potential impacts associated with the proposed recreational facilities improvements are considered less than significant. Overall, the addition of bike lane would result in beneficial impacts in regard to recreational opportunities and connectivity in the region. As such, physical effects on the environments as a result of the Proposed P roject would be less than significant and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

3.16.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

SEIR No. 332 mitigation measures are not applicable to the Proposed Project.

Mitigation Measures from SEIR No. 339

SEIR No. 339 mitigation measures are not applicable to the Proposed Project.

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Final | March 2022 3-87 Environmental Analysis

3.17 TRANSPORTATION

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Conflict with a program, plan, ordinance or policy
addressing the circulation system, including transit,
roadway, bicycle, and pedestrian facilities?

b. Conflict or be inconsistent with CEQA Guidelines
section 15064.3, subdivision (b)? 
c. Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?

d. Result in inadequate emergency access? 

As discussed in Section 3.0 , Project implementation would widen Orangewood Avenue from a five-lane roadway to a six-lane d ivided facility to provide expanded vehicle, bicycle, and pedestrian access , and annexation of land near the Santa Ana River; refer to Exhibit 2 -3. The Project would incorporate an additional westbound through lane through the Project Site boundaries to ensure acceptable operations through the Project area and accommodate the PTMLUP’s proposed land use intensities . Proje ct implementation would improve queuing along Orangewood Avenue; however, the proposed additional westbound through lane would not increase roadway capacity along the affected segment.

Orangewood Avenue is a west-east roadway with two travel lanes in each direction. The posted speed limit along the affected roadway segment is 40 miles per hour. The Anaheim General Plan Circulation Element identifies the roadway as a Primary Arterial and the Orange General Plan Circulation and Mobility Element identifies the roadway as a Primary Arterial west of Eckhoff Street and a Major Arterial east of Eckhoff Street. The Orange General Plan and Anaheim General Plan designate the cross section for a Primary Arterial as a four-lane divided roadway with 115 feet of right-of-way and the Orange General Plan designates the cross section for a Major Arterial as a six-lane divided roadway.

The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization portion of the Project reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

a) Would the project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities ?

Th
is impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 on page 5.9-39.

SEIR No. 339 concluded that PTMLUP build-out
of would increase traffic volumes on Caltrans facilities and thus would conflict with an applicable congestion management program.

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Pre
vious Significance Determination: SEIR No. 339 concluded that PTMLUP build-out of would increase traffic volumes on Caltrans facilities and thus would conflict with an applicable congestion management program. SEIR No. 339 also concluded that PTMLUP buildout would impact the level of service for the area roadway system and therefore would conflict with an applicable plan, ordinance, or policy establishing the effectiveness for the performance of the circulation system. Despite incorporation of SEIR No. 339 MM 9-1 t
hrough MM 9-15, im
pacts related to the level of service for the area roadway system and increased traffic volumes on C altrans facilities were determined to remain significant and unavoidable, and a Statement of Overriding Considerations was adopted by the City Council when SEIR No. 339 was certified.

Project‐Specific Analysis:

LOCAL LEVEL OF SERVICE CONSISTENCY

The objective of the Proposed Project is to accommodate existing and predicted traffic flows associated with PTMLUP buildout by widening Orangewood Avenue from a five -lane facility to six lanes generally from the Santa Ana River to just east of SR-57 at the SR-57/Orangewood Avenue interchange. Although the Project would be designed to accommodate additional traffic volumes, the proposed improvements would not directly generate new traffic or increase the number of vehicles along the roadway.

Additionally, as the Project would improve intersection level of service and reduce queueing, the Project would not conflict with (i.e. lower) an established measure of effectiveness for performance of the system (i.e. level of service) . I nstead, Project implementation would improve conditions along the roadway, allowing for improved traffic flows and circulation. As a roadway widening Project, SEIR No. 339 MM 9- 1 through MM 9 -15 are not applicable to the Proposed Project because the Project implementation would not result in traffic impacts.

The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

For the reasons above, the Project would not conflict with an applicable plan, ordinance, or policy establishing measures of effectiveness for the performance of the affected circulation system and the level of impacts would not increase from that identified in SEIR No. 339.

REGIONAL CMP CONSISTENCY

Orange County Transportation Agency (OCTA) is charged with adopting the Orange County Congestion Management Plan (CMP). In the City of Anaheim, CMP facilities include Harbor Boulevard, State College Boulevard, Katella Avenue, Tustin Avenue, Orangethorpe Avenue, Beach Boulevard, Imperial Highway, as they intersect with I-5, SR-57, and SR-91. In the City of Orange, the only CMP facilities include the SR -55 northbound and southbound ramps at Katella Avenue.
14 14 Orange County Transportation Authority, 2015 Orange County Congestion Management Program, Figure 4: CMP Level of Service Chart, November 2015.

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The Proposed Project would affect an approximately half- mile long segment of Orangewood Avenue, which is not designated as a CMP facility by the OCTA. The Project would widen a segment of Orangewood Avenue to accommodate existing and predicted traffic associated with PTMLUP buildout.

Therefore, the proposed improvements would further the long -term transportation needs identified by SEIR No. 339 to ensure transportation infrastructure can adequately meet the demands associated with PTMLUP buildout. As discussed, SEIR No. 339 MM 9 -1 through MM 9 -15 are not applicable to the Proposed Project because the Project implementation would not result in traffic impacts. The Project would not conflict with an applicable congestion management program, and the level of impact would not increase from that identified in SEIR No. 339.

The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?

In September 2013, the Governor’s Office of Planning and Research (OPR) signed SB 743 into law, starting a process that fundamentally changes the way transportation impact analysis is conducted under CEQA.

These changes include the elimination of auto delay, LOS, and similar measurements of vehicular roadway capacity and traffic congestion as the basis for determining significant impacts. The guidance identifies Vehicle Miles Travelled (VMT) as the most appropriate CEQA transportation metric, along with the elimination of auto delay and LOS for CEQA purposes. The justification for this paradigm shift is that auto delay/LOS impacts lead to improvements that increase roadway capacity and therefore induce more traffic and greenhouse gas emissions.

The previously certified SEIR No. 339 did not evaluate VMT as it was not required in the CEQA Guidelines at the time SEIR No. 339 was prepared.

On October 26, 2010, the City of Anaheim certified the SEIR No. 339 that analyzed the potential impacts associated with development of the revised Platinum Triangle Expansion Project. Although this previous environmental document did not include a VMT analysis, a supplemental environmental analysis of VMT impacts cannot be required absent new information on that front. The implementation of project design features and mitigation measures related to vehicle emissions have typically been incorporated into air quality and greenhouse gas emissions analyses. Thus, the effect of increased VMT could have been raised in 2010 when the City considered the EIR. A challenge to an EIR must be brought within 30 days of the lead agency’s notice of approval. (Pub. Resources Code, § 21167[b].) Under Public Resources Code Section 21166(c), an agency may not require a supplemental envir onmental review unless new information, which was not known and could not have been known at the time the EIR was approved, becomes available. After a project has been subjected to environmental review, the statutory presumption flips in favor of the proj ect proponent and against further review. (Moss v. County of Humboldt [2008] 162 Cal.App.4th 1041, 1049-1050.) “‘[S]ection 21166 comes into play precisely because in-depth review has already occurred [and] the time for challenging the sufficiency of the original EIR has long since expired.’” (Id., 1050.) There is no competent evidence of new information of severe impact,

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and thus the City may rely on an addendum. Accordingly, the City finds that VMT is not “new information” under Public Resources Code Section 21166.

Previous Significance Determination: SEIR No. 339 concluded that although PTMLUP buildout could result in an increase in vehicle miles traveled (VMT) and trips in the local area, the PTMLUP would benefit to the Southern California Association Government (SCAG) region as it would allow for housing opportunities closer to employment centers. SEIR No. 339 determined that the PTMLUP would therefore be consistent with SCAG’s strategies to reduce VMT in the SCAG region and would be consistent with Southern California Air Quality Management District’s 2007 Air Quality Management Plan (2007 AQMP), which was the applicable air quality plan at the time. Impacts concerning conflicting with or obstructing implementation of the SCAQMD’s 2007 AQMP were identified as less than significant, and no mitigation was identified.

SE
IR No. 339 also concluded that PTMLUP buildout had the potential to generate greenhouse gas (GHG) emissions, either directly or indirectly (including VMT consideration), that may have a significant impact on the environment. Specifically, SEIR No. 339 found that the project evaluated in the SEIR would generate substantially more GHG emissions compared to the adopted PTMLUP and would cumulatively contribute to clima te change impacts in California. Mitigation measures from several environmental sections of SEIR No. 339 were identified to reduce GHG emissions, including: MM 2-3, MM 2-5,
MM 2-6,
MM
9-1, M
M 9-2,
MM 9-12,
MM 9-14,
MM 10-7,
MM 10-9, MM
10-12, MM
10-13,
MM 10-14,
MM 10-
18,
MM 10 -19,
MM 10 -20, M
M 10 -21, MM
10 -22,
and MM 10 -24.

Despite implementation of the
abovementioned mitigation measures , impacts related to GHG emissions were deter mined to remain significant and unavoidable, and a Statement of Overriding Considerations was adopted by the City Council when SEIR No. 339 was certified.

Project‐Specific Analysis: As discussed above, SEIR No. 339 did not address VMT as it was not required in the CEQA Guidelines at the time SEIR No. 339 was prepared. Construction of the Proposed Project would widen the existing bridge structure to increase traffic flow through the Project area and increase efficiency through the intersections. The proposed roadway widening would accommodate existing and predicted traffic demands in compliance with SEIR No. 339 MM 2-5 and would not directly generate new traffic or increase the numbers of vehicles along the roadway. Further, it is acknowledged that OPR has adopted VMT screening criteria to determine if a project require s a detailed VMT analysis pursuant to the Technical Advisory on Evaluating Transportation Impacts in CEQA (Technical Advisory), dated April 16, 2018. Per the Technical Advisory, projects that would not likely lead to a substantial or measurable increase in vehicle travel, and therefore generally should not require an induced travel analysis, include:

• Rehabilitation, maintenance, replacement and repair projects designed to improve the condition of existing transportation assets (e.g., highways, roadways, bridges, culverts, tunnels, transit systems, and assets that serve bicycle and pedestrian facilities) and that do not add additional motor vehicle capacity.

As the Proposed Project is replacing the existing bridge structure, improving transportation assets (including bicycle and pedestrian facilities), and would not add additional motor vehicle capacity beyond what was considered in SEIR No. 339, a VMT analysis would not be required. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subje ct to the reorganization would be subject to analysis pursuant to CEQA.

Given that the permitted type and intensity of development would be similar to what was previously - analyzed by SEIR No. 339, one can anticipate that the Project would not generate additional VMT beyond

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SEIR No. 339 conditions and would not conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b). No impact would occur in this regard.

Significance Determination: No increase in significant impacts has resulted.

c) Would the project substantially increase haz ards d ue to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 page 5.9-105.

Pre
vious Significance Determination: SEIR No. 339 concluded that PTMLUP implementation would not create sharp curves, dangerous intersections, or any other inherently hazardous design features. SEIR No. 339 determined in accordance with MMP No. 106C, the property owner/developer would dedicate, including necessary construction easements, the ultimate arterial highway rights-of-way as s hown in the
Circulation Element of the Anaheim General Plan adjacent to their property to maintain adequate levels of service and access with the Platinum Triangle. Impacts associated with hazardous geometric design features or incompatible land uses were considered less than significant with incorporation of SEIR No. 339 MM 9-16 a
nd MM 9-17.

Project‐Specific Analysis: Refer to Response 3.16 (a). The Project would widen an existing linear segment of Orangewood Avenue that does not presently include sharp curves. In addition, the proposed roadway improvements would not introduce a hazardous design feature such as sharp curves or dangerous intersections. Project implementation is intended to support existing and predicted traffic levels associated with buildout of the PTMLUP, and would improve intersection LOS and reduce queueing to improve safety on the roadway. As discussed under Response 3.16 (a), SEIR No. 339 MM 9 -16 and MM 9 -17 are not applicable to the Proposed Project . Thus, Project implementation would not substantially increase hazards due to a geometric design feature or incompatible use and the level of impact would not increase from that identified in SEIR No. 339.

Th
e land uses associated with the annexation of land in the Santa Ana River area would be compatible with the existing land uses in the Project vicinity. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

d) Would the project result in inadequate emergency access?

Previous Significance Determination: SEIR No. 339 concluded that the PTMLUP’s proposed roadway system is de signed to accommodate the i ncreased traffic volumes and ea ch development project is required to provide appropriate fire and emergency access, as approved by the AFD. All vehicle access would be d esigned and improved in accordance with the requirements of the City Engineer. Impacts concerning emergency access were determined to be less than significant.

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Project‐Specific Analysis: Refer to Responses 3.16 (a) and 3.16 (b). The Project would include improvements along an approximately half- mile segment of Orangewood Avenue . Temporary lane closures, if any, could have the potential to impact emergency vehicle access to adjacent properties due to temporary lane closures. However, Project implementation would contribute to enhanced emergency access along Orangewood Avenue by improving existing traffic conditions and accommodating future traffic generated from PTLUMP buildout. Pursuant to Orange Municipal Code Section 12.64, Encroachments in the Public Rights -of-Way, all improvements occurring within Orange right -of-way would require an encroachment permit issued by the Director of Public Works. All improvements occurring within City of Anaheim right-of-way would require preparation of a Right-of-Way Construction Application for approval by the Director of Public Works. As Project construction would obtain all necessary permits from each respective jurisdiction, the Project ’s construction and operational impacts concerning emergency access would be less than significant, and the level of impact would not increase from that identified in SEIR No. 339.

The land uses associated with the annexation of land in the Santa Ana River area would be compatible with the existing land uses in the Project vicinity. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

3.17.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

SEIR No. 332 mitigation measures are not applicable to the Proposed Project.

Mitigation Measures from SEIR No. 339

SEIR No. 339 mitigation measures are not applicable to the Proposed Project.

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Final | March 2022 3-93 Environmental Analysis

3.18 TRIBAL CULTURAL RESOURCES

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a
site, feature, place, cultural landsc
ape that is
geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural
value to a California Native American tribe, and that is:

1) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section
5020.1(k), or

2) A resource determined by the lead agency, in its
discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying
the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider
the significance of the resource to a California Native American tribe.


In 2004, the Governor of California signed into law Senate Bill 18 (SB18) which requires that, prior to the adoption or amendment of a city or county’s general plan, the city or county conduct consultations with California Native American tribes for the purpose of preserving specified places, features, and objects that are located within the city or county’s jurisdiction. SB 18 refers to PRC 5097.9 and 5097.995 (remunerated to PRC 5097.993), which defines a cultural place as:

• Any Native American Sanctified Cemetery, place of worship, religious or ceremonial site or sacred shrine located on public property.

• Native American historic, cultural, or sacred site, that is listed or may be eligible for listing in the California Register of Historic Resources pursuant to Section 5024.1, including any historic or prehistoric ruins, any burial ground, and any archaeological or historic site.

SB 18’s intent is to facilitate meaningful consultation between tribal governments and local governments at the earliest point of the planning and application process. The Native American Heritage Commission (NAHC) maintains a list of California Native American Tribes and pursuant to Government Code Section 65352.3, prior to the adoptio n or any amendment of a city’s or county’s general plan, proposed on or after March 1, 2005, the city or county shall conduct consultations with California Native American tribes that are on NAHC’s contact list. From the date of city or county who contacts the California Native American tribe, the tribe has 90 days to request a consultation, unless that tribe has agreed to a shorter timeframe. Additionally, pursuant to Government Code Section 65040.02, the city or county shall protect the confidentiality of information concerning the specific identify, location, character and use of those places, features, and objects.

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The City of Anaheim recognizes the requirements of SB 18 and the purpose of preserving, mitigating impacts and identifying cultural places located on the project site and in relation to General Plan Amendments associated with the proposed project. Implementation of these requirements is described below.

In 2014, the governor of California approved AB 52, which expanded CEQA by establishing a formal consultation process for California tribes within the CEQA process. The bill specifies that any project may affect or cause a substantial adverse change in the significance of a tribal cultural resource would require a lead agency to “begin consul tation with a California Native American tribe that is traditional and culturally affiliated with the geographic area of the Proposed Project.” Section 21074 of AB 52 also defines a new category of resources under CEQA called “tribal cultural resources.” Tribal cultural resources are defined as “sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe” and is either listed on or eligible for the California Register of Historical Resources or a local historic register, or if the lead agency chooses to treat the resource as a tribal cultural resource.

AB 52 specific that a project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource, as defined, is a project that may have a significant effect on the environment.

The bill requires a lead agency to begin consultation with a California Native American tribe that is traditionally and culturally affiliated with the geographic area of the proposed project, if the tribe requested to the lead agency, in writing, to be informed by the lead agency of proposed projects in that geographic area and the tribe requests consultation, prior to determining whether a negative declaration, mitigated negative declaration, or environmental impact report is required for a project. These requirements apply to projects that have a notice of preparation or a notice of negative declaration filed or mitigated negative declaration on or after July 1, 2015. Thus, since this is an addendum to a previously- certified EIR, AB 52 does not apply to this Project.

On Tuesday, May 25, 2021, the City submitted and initiated a Tribal Consultation List request for a list of California Native American tribes’ contacts and a Sacred Lands File (SLF) search from the NAHC. On Thursday, June 10, 2021, the NAHC responded to th e City’s request and returned a populated Tribal Consultation List with California Native American Tribes’ contact information for tribes that have traditional lands or cultural places within the boundaries of the county (Orange County), which the project site is located within. Additionally, NAHC returned results for the SLF and the results came back negative.

The City wrote SB 18 notification letters to all of the tribes listed on the Tribal Consultation List that NAHC provided. The letters explain the pr oposed project, which includes General Plan amendments as part of this City initiated action. On Tuesday, June 15, 2021, the City emailed and certified mailed physical copies of these letters to the tribes on the Tribal Consultation List. Refer to Appendi x E, SB 18 Consultation Memorandum.

To date, only two tribes have responded to the City’s SB 18 notification letters. The City also took effort to facilitate consultation efforts, to ensure and confirm if any tribes contacted wanted to proceed with consultation or defer not to have consultation. The City sent out follow up emails asking the tribes to provide confirmation of consultation interest or deferral on Wednesday, July 21, 2021 and on Tuesday, August 10, 2021. As mentioned previously, only two tribe s responded to the City’s SB 18 notification letters.

• Gabrieleno Band of Mission Indians – Kizh Nation (Kizh Nation): On Wednesday, June 16, 2021, Kizh Nation responded to the City’s SB 18 notification via email, asking for clarifications behind the proposed project’s activities. Upon the City clarifying details for Kizh Nation, they decided that

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there would be no need for consultation and communicated that via email on Tuesday, June 22, 2021.

• Pala Band of Mission Indians (Pala Band): On Wednesday, June 21, 2021, Pala Band responded to the City’s July 21, 2021 SB 18 follow up email, with an attached letter stating, in summation – that they would be not requesting consultation.

No other tribe has contacted the City since the latest August 10, 2021 follow up email.

The 90 day window for consultation request closed on September 14, 2021.

a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:

1) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or

Previous Significance Determination: At the time of the release of the Notice of Preparation for SEIR No. 339, Appendix G of the CEQA Guidelines did not include environme ntal issues regarding potential impacts to Native American-related historical resources. As discussed in Response 3.5 (a), the Initial Study for SEIR No. 339 concluded that the Platinum Triangle does not contain any historical resources as defined by CEQA Guidelines Section 15064.5. The Platinum Triangle is not located within the Anaheim Colony Historic District and none of the structures within the PTMLUP area were identified on the Qualified Historic Structures list of the Anaheim Colony Historic Distric t Preservation Plan. No known historic archaeological sites within the PTMLUP were identified. The Initial Study concluded that no impacts would occur and no mitigation was necessary. Because there were no impacts, these resources were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: As discussed above, SEIR No. 339 did not address tribal cultural resources.

However, according FSEIR No. 332, the PTMLUP does not have any historical resources as defined in CEQA Guidelines Section 15064.5. Also, there are no historic archaeological sites located within the PTMLUP and the potential for any subsurface cultural resources is considered remote . According to Orange General Plan EIR Figure 5.5-1 (Designated Historic Resources) and Section 5.4, Cultural Resources, of the Anaheim General Plan EIR, no historical or archaeological resources have been identified in the Project vicinity. As the Project involves a fully-improved segment of Orangewood Avenue, a disturbed area near the Santa Ana River (associated with the annexation of land adjacent to the Santa Ana River), as well as a channelized portion of the Santa Ana River , the Project’s impacts concerning Native American- related historical resources would be less than significant, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

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2) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Previous Significance Determination: At the time of the release of the Notice of Preparation for SEIR No. 339, CEQA Guidelines Appendix G did not include environmental issues regarding potential impacts to tribal cultural resources. Therefore, tribal cultural resources were not evaluated in SEIR No. 339.

Project‐Specific Analysis: As discussed above, the Project is not subject to AB 52 and did not undergo the AB 52 consultation process. Nonetheless, no Native American historical or archaeological resources were identified within the Project vicinity as part of SEIR No. 339 and no new impacts have been identified since certification of SEIR No. 339 . As the Project involves a fully -improved segment of Orangewood Avenue, a disturbed area near the Santa Ana River (associated with the annexation of land adjacent to the Santa Ana River), as well as a channelized portion of the Santa Ana River, the Project ’s impacts concerning Native American-resources would be less than significant, and the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

3.18.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

At the time of the release of the Notice of Preparation for SEIR No. 332, CEQA Guidelines Appendix G did not include environmental issues regarding tribal cultural resources. Therefore, tribal cultural resources were not evaluated in SEIR No. 332. No impacts would occur and no mitigation is required.

Mitigation Measures from SEIR No. 339

At the time of the release of the Notice of Preparation for SEIR No. 339, CEQA Guidelines Appendix G did not include environmental issues regarding tribal cultural resources. Therefore, tribal cultural resources were not evaluated in SEIR No. 339. No impacts would occur and no mitigation is required.

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3.19 UTILITIES AND SERVICE SYSTEMS

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater
drainage, electric power, natural gas, or
telecommunications facilities, the construction or
relocation of which could cause significant
environmental effects?

b. Have sufficient water supplies available to serve the project and reasonably foreseeable future development
during normal, dry, and multiple dry years?

c. Result in a determination by the wastewater treatment provider which serves or may serve the project that it
has adequate capacity to serve the project’s projected
demand in addition to the provider’s existing
commitments?

d Generate solid waste in excess of state or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of solid waste reduction goals?

e. Comply with federal, state, and local management and reduction statutes and regulations related to solid
waste?


The SEIR No. 339 identified the following utility agencies that provide service within the PTMLUP area.

• Wastewater Treatment and Collection (Anaheim Public Utilities Department); • Water Supply and Distribution Systems (Anaheim Public Utilities Department); • Solid Waste (Republic Waste Services of Southern California, LLC); • Electricity (Anaheim Public Utilities Department);
• Natural Gas (Southern California Gas Company); and
• Communications (Time Warner and AT&T).

a) Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 on pages 5.10-22,

5.10-27, 5.10-33, 5.10-34, and 5.10-36 of SEIR No. 339.

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Orangewood Avenue Improvements

Final | March 2022 3-98 Environmental Analysis
Previous Significance Determination:

WATER FACILITIES

SEIR No
. 339 de termined that buildout of the PTMLUP would require the addition of new water facilities. T he SE IR determined that compliance with Rule 15-D wo uld ensure that adequate water facilities are provided to serve the PTMLUP. SEIR No. 339 found impacts associated with new or expanded water facilities to be less than significant with incorporation of SEIR No. 339 MMs 10-1 t hrough 10-16.

WA

STEWATER TREATMENT FACILITIES

SEIR No
. 339 de termined that buildout of the PTMLUP would require sewer improvements. With implementation of improvements, the sewer system, in cluding sewer treatment, was anticipated to accommodate development within the PTMLUP area based on future buildout conditions. SEIR No. 339 found impacts associated with new or expanded wastewater treatment facilities to be less than significant with incorporation of SEIR No. 339 MMs 10-1 th rough 10-16.

ST

ORMWATER DRAINAGE FACILITIES

SEIR No. 339 noted that the Master Plan of Storm Drainage for East Garden Grove Wintersburg Channel Tributary Ar ea i dentified that the e xisting sto rm drainage system was deficie nt u nder the existing conditions in the PTMLUP area at the time the SEIR was prepared. SEIR No. 339 concluded that construction of sto rm drain facilities would o ccur in compliance with the standard engineering r ules and regulations and would not result in a significant environmental effect. Impacts associated with stormwater drainage facilities were determined to be less than significant with incorporation of SEIR No. 339 MM 10-17
.

DR

Y UTILITIES

According to SEIR No. 339, the PTMLUP area receives electricity, natural gas, and telecommunication services from APUD, Southern California Gas Company (SoCal Gas), and Time Warner and AT&T, respectively. SEIR No. 339 determined that project implementatio n would require the construction of electricity, natural gas, and telecommunication facilities. Impacts associated with dry utilities were determined to be less than significant with incorporation of SEIR No. 332 MM 10 -21 through 10-24 and SERI No. 339 MM 10-25 through 10-27.

Project‐Specific Analysis:

WATER FACILITIES

Due to the nature of the Project (roadway widening and annexation of land adjacent to the Santa Ana River), Project implementation would not require or result in the construction of new water facilities or expansion of existing facilities. The Project does not propose landscaped medians or any other component which would require water connections. T he Project would install a water line connection within Orangewood Avenue to enhance the City of Orange’s existing water system. The proposed water line connection would provide redundancy should failure arise in other areas of the system and would not involve a capacity increase which would require or result in the construction of new water facilities or expansion of existing facilities, the construction of which could cause an environmental effect. No impact would occur in this regard, and the level of impact would not increase from that identified in SEIR No. 339.

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Orangewood Avenue Improvements

Final | March 2022 3-99 Environmental Analysis

WASTEWATER TREATMENT FACILITIES

Due to the nature of the Project (roadway widening and annexation of land adjacent to the Santa Ana River), Project implementation would not require or result in the construction of new wastewater treatment facilities or expansion of existing facilities. No impact would occur in this regard, and the level of impact would not increase from that identified in SEIR No. 339.

STORMWATER DRAINAGE FACILITIES

To accommodate widening of the Orangewood Avenue bridge crossing, an existing drainage facility located at the eastern portion of the Santa Ana River would need to be relocated slightly north of the existing location. Roadway widening activities would also install curb, gutter, and storm drain improvements along the affected segment of Orangewo od Avenue. Excluding the existing Santa Ana River Trial drainage facility, all storm drain improvements would occur within the existing heavily disturbed roadway right -of-way. Any potentially significant effects resulting from the Project’s storm drain improvements are analyzed in this Addendum and SEIR No. 339 and mitigated as appropriate. Thus, although the Project would involve the construction and relocation of stormwater drainage facilities, construction itself would not result in a significant environmental effect. Impacts would be less than significant in this regard, and the level of impact would not increase from that identified in SEIR No. 339.

DRY UTILITIES

As a roadway widening and annexation project, Project implementation would not increase demands on natural gas and telecommunication facilities. As a result, the Project would not require or result in the relocation or construction of new or expanded electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects . No impacts would occur in this regard, and the level of impact would not increase from that identified in SEIR No. 339.

Santa Ana River Reorganization

The land uses associated with the annexation of land in the Santa Ana River area would be compatible with the existing land uses in the Project vicinity The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensit y of development would be similar to what was previously -analyzed by SEIR No. 339, one can anticipate that the level of impact to water, wastewater treatment and stormwater drainage facilities, as well as dry utilities, would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

b) Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 page 5.10-27.

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Orangewood Avenue Improvements

Final | March 2022 3-100 Environmental Analysis
Previous Significance Determ ination: SEIR No. 3 39 determined that based on the Water Su pply Assessment for the PTMLUP, there would be surplus water through the 20-year pla nning period. The SEIR
impacts associated with water supplies to be less than significant with incorporation of SEIR No. 339 MMs 10-7 t
hrough 10-16.

Project‐Specific Analysis: As a roadway widening and annexation project, Project implementation would not increase demands on existing water service facilities. The Project does not entail a land use which would require the provision or expansion of water services. Although minimal, water may be used for dust suppression purposes during Project construction; however, sufficient water supplies are available to serve such purposes from existing entitlements and resources. As discussed, the Project does not propose landscaped medians or any other component which would require water connections. The Project would install a water line connection within Orangewood Avenue to enhance the City of Orange’s existing water system. The proposed water line connection would provide redundancy should failure arise in other areas of the system and would not involve a capacity increase which would require new or expanded water supply entitlements. No impact would occur in this regard, and the level of impact would not increase from that identified in SEIR No. 339.

The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

c) Would the project result in a determ ination by the w astewater treatment provider, which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?

Previous Significance Determination: SEIR No. 339 de termined that buildout of the PTMLUP would require sewer improvements. With implementation of improvements, the sewer system, including sewer treatment, was anticipated to accommodate development within the PTMLUP area based on future buildout conditions. SEIR No. 339 found impacts associated with wastewater treatment service to be less than significant with the incorporation of SEIR No. 339 MMs 10-1 t hrough 10-6.

Project‐Specific Analysis: Refer to Response 3.18 (b). As a roadway widening project, the proposed improvements would not increase demand on existing wastewater treatment facilities. The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339. Therefore, no impact would occur and the level of impact associated with the proposed project would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Orangewood Avenue Improvements

Final | March 2022 3-101 Environmental Analysis
d) Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 on page 5.10-33.

Pr
evious Significance Determination : SEIR No. 339 determined that the Olinda Alpha Landfill is the closest facility to the PTMLUP area and would be the solid waste facility most often r eceiving waste from the area. Implementation of the PTMLUP would increase the service demand for solid waste disposal beyond existing conditions and would provide more solid waste to the Olinda Alpha Landfill. The SEIR concluded that there would be available landfill capacity in the Orange County landfi ll system to accommodate the anticipated solid waste stream generated by implementation of the PTMLUP. SEIR No. 339 found impacts associated with landfill capacity to be less than significant with the incorporation of SEIR No. 339 MMs 10-18 thr
ough 10-20.

Project‐Specific Analysis: The City of Anaheim disposes over 99 percent of the City’s solid waste at the five landfills identified in Table 3.19-1, Landfills Summary. The five landfills serving Anaheim have a total permitted capacity of approximately 7.2 million cubic yards plus an additional 45,554 tons per day permitted capacity and a remaining capacity of approximately 4.4 million cubic yards.

Table 3.19-1
Landfills Summary

Facility
Amount Disposed
from Anaheim
in 20181
Permitted Throughput
(tons/day)2
Permitted Capacity
(cubic yards, unless
otherwise noted)2
Remaining Capacity
(cubic yards)2
Azusa Land Reclamation
Co. Landfill 2,558 8,000 80,571,760 51,512,201
El Sobrante Landfill 3,809 16,054 209,910,000 143,977,170 Frank R. Bowerman
Sanitary Landfill 12,439 11,500 266,000,000 205,000,000 H.M. Holloway Inc. 70,040 2,000 12,600,000 7,522,934
Olinda Alpha Sanitary
Landfill 386,433 8,000 148,800,000 34,200,000
TOTAL 475,279 45,554 717,881,760 442,212,305
Note:

1. CalRecycle Website, Disposal Reporting System (DRS): Jurisdiction Disposal and Alternative Daily Cover (ADC) Tons by Faci lity, https://www2.calrecycle.ca.gov/LGCentral/DisposalReporting/Destination/DisposalByFacility, Accessed August 28, 2019.

2. Solid Waste Information System (SWIS), Integrated Waste Management Board, https://www2.calrecycle.ca.gov/swfacilities/Directory/19-AA- 0013/Index, Accessed August 28, 2019.

Project construction would involve limited amounts of demolition/excavation of existing materials and soils which would require solid waste hauling. The volume of existing materials and soils is not anticipated to be substantially larger than that identified in SEIR No. 339 such that surrounding landfills identified in Table 3.1 9-1 would be overburdened by the Project’s solid waste disposal needs. The disposal of excavation and construction debris would be subject to compliance with all Federal, State, and local statutes and regulations related to solid waste, including the 50 percent diversion of solid waste requirement pursuant to the California Integrated Waste Management Act of 1989 (AB 939).

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
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Final | March 2022 3-102 Environmental Analysis
Pursuant to AB 939, the City of Anaheim and the City of Orange have each prepared a Source Reduction and Recycling Element (SSRE). Both cities implement their SRRE to ensure that their respective solid waste reduction goals continue to be met. The proposed Project would be required to comply with such goals stipulated under each City’s SRRE for diverting solid waste, as applicable. With incorporation of applicable mitigation measures identified under SEIR No. 339, impacts concerning compliance with the statutes and regulations in place relative to solid waste disposal would be less than significant, and the level of impact would not increase from that identified in SEIR No. 339.

The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

d) Would the project comply with Federal, State, and local management and reduction statutes and regulations related to solid waste ?

This impact threshold was modified by the OPR in 2018. The changes to this threshold of significance consist of refinements and clarifications of existing requirements. Although the specific language for this threshold of significance has changed, the analysis was considered in the SEIR No. 339 on page 5.10- 33 of SEIR No. 339.

Pre
vious Significance Determination: SEIR No. 339 concluded that implementation of the PTMLUP would generate increased construction and o perational solid waste in the area, so therefore each development project in the PTMLUP area would be required to submit project plans to the S treets and Sanitation Division of the Public Works Department for review and approval to ensure that the plans comply with the Solid Waste Act of 1989 (AB 939) and the County of Orange and the City of Ana heim Integrated Waste Management Program, as administered by the City of Anaheim. SEIR No. 339 found impacts associated with solid wa ste statutes and regulations to be less than significant with incorporation of SEIR No. 339 MMs 10-18 th
rough 10-20.

Project‐Specific Analysis: Refer to Response 3.1 9 (d ). Project construction would be subject to conformance with the City o f Anaheim and City of Orange’s adopted construction and solid waste disposal programs and well as applicable Federal, State, and local regulations concerning solid waste. A less than significant impact would occur, and the level of impact would not increase from that identified in SEIR No. 339.

The proposed amendments to the General Plan, Zoning Map and PTMLUP associated with the Santa Ana River reorganization reflect anticipated future development of these areas, but not a specific development project. Any future development of the area subject to the reorganization would be subject to analysis pursuant to CEQA. Given that the permitted type and intensity of development would be similar to what was previously-analyzed by SEIR No. 339, one can anticipate that the level of impact would not increase from that identified in SEIR No. 339.

Significance Determination: No substantial increase in the level of impact from previous analysis.

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Orangewood Avenue Improvements

Final | March 2022 3-103 Environmental Analysis

3.19.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

Refer to the Mitigation Measures from SEIR No. 339 below, which are based on adopted Mitigation Measures from SEIR No. 332.

Mitigation Measures from SEIR No. 339

SEIR No. 339 includes measures to reduce potential impacts associated the development and infrastructure improvements within the Platinum T riangle. T he following mitigation measures are applicable.
15 Any modifications to the original measures are shown in strikethrough for deleted text and new, inserted text is underlined.

MM 10-2 Prior to the approva l and ongoing du ring co nstruction of any st reet improvement plans within the Platinu m Triangle, wh ich encompass area(s) where Orange County Sanitation District (OCSD) will be upsizing t runk li nes and/or are making other impr ovements, the City of Anaheim a nd/or property owner/develope r shall c oordinat e wi th the OCSD to ensure tha t all improveme nts and construction schedules are coordinate d.

MM 10-5 Prio r to the a pproval and ongoing during construction of any str eet improvement plans within the Platinum Triangle, which encompass area(s) where the Orange County Sanitation District (OCSD) will be upsizing trunk lines and/or are making other improvements, the City of Anaheim and/or property owner shall coordinate with OCSD to ensure that backflow prevention devices are installed at the lateral connections to prevent surcharge flow from entering private properties.

MM 10-18 P rior to the final building and zoning inspections of each development, the property owner/developer shall submit project plans to the Streets and Sanitation Division of the Public Works Department for review and approval to ensure that the Public Works Department, Development Services Division shall confirm all plans submitted during Plans, Specifications, and Estimate phase comply with AB939, and the Solid Waste Reduction Act of 1989, and the County of Orange and City of Anaheim Integrated Waste Management Plans as administered by the City of Anaheim. Implementation of said plan shall commence upon occupancy and shall remain in full effect as required by the Street and Sanitation Division and may include, at its discretion, the following plan components:

• Detailing the locations and design of on-site recycling facilities. • Participating in the City of Anaheim’s “Recycle Anaheim” program or other substitute program as may be developed by the City or governing agency. • Facilitating cardboard recycling (especially in retail areas) by providing adequate space and centralized locations for collection and bailing.
• Providing trash compactors for nonrecyclable materials whenever feasible to reduce the total volume of solid waste and number of trips required for collection. • Providing on-site recycling receptacles accessible to the public to encourage recycling for all businesses, employees, and patrons where feasible.

15 Mitigation measure numbering corresponds to Platinum Triangle Master Land Use Plan Appendix C, Updated and Modified Mitigation Monitoring Program Number 106C.

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Final | March 2022 3-104 Environmental Analysis
• Prohibiting curbside pick-up.
• Ensuring hazardous materials disposal complies with Federal, State, and city regulations.

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Orangewood Avenue Improvements

Final | March 2022 3-105 Environmental Analysis

3.20 WILDFIRE

SEIR No. 339 did not evaluate as it was not required in the CEQA Guidelines at the time SEIR No. 339 was prepared.

On October 26, 2010, the City of Anaheim certified the SEIR No. 339 that analyzed the potential impacts associated with development of the revised Platinum Triangle Expansion Project. Although this previous environmental document did not include a specific wildfire analysis, a supplemental environmental analysis of wildfire impacts cannot be required absent new information on that front. The implementation of project design features and mitigation measures related to wildfire have typically been incorporated into hazard and hazardous materials analysis. Thus, the effect of wildfires would have been raised in 2010 when the City considered the EIR. A challenge to an EIR must be brought within 30 days of the lead agency’s notice of approval. (Pub. Resources Code, § 21167[b].) Under Public Resources Code Section 21166(c), an agency may not require a supplemental environmental review unless new information, which was not known and could not have been known at the time the EIR was approved, becomes available.

After a project has been subjected to environmental review, the statutory presumption flips in favor of the project proponent and against further review. (Moss v. County of Humboldt [2008] 162 Cal.App.4th 1041, 1049- 1050.) “‘[S]ection 21166 comes into play precisely because in -depth review has already occurred [and] the time for challenging the sufficiency of the original EIR has long since expired.’” (Id., 1050.) There is no competent evidence of new information of severe impact, and thus the City may rely on an addendum. Accordingly, the City finds that wildfire is not “new information” under Public Resources Code Section 21166.

If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Substantially impair an adopted emergency response
plan or emergency evacuation plan? 
b. Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project
occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?

c. Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency
water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?

d. Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post -fire slope
instability, or drainage changes?


a) Would the project s ubstantially impair an adopted emergency response plan or emergency evacuation plan?

Previous Significance Determination: The Initial Study for SEIR No. 339 concluded that PTMLUP buildout would not expose people or structures to significant risk of loss, injury or death involving

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
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Final | March 2022 3-106 Environmental Analysis
wildland fires since the PTMLUP area is developed and no undeveloped wildland areas are in or adjacent to the PTMLUP area. Because there were no impacts, they were not further analyzed in SEIR No. 339.

Project‐Specific Analysis: The Project Site is not located within or near a State responsibility area.

According to the California Department of Forestry and Fire Protection’s Very High Fire Hazard Severity Zones in LRA Map for Anaheim, the Project Site is not located within a Very High Fire Hazard Severity Zone.16 No impacts would occur in this regard.

Significance Determination: No substantial increase in the level of impact from previous analysis.

b) Due to slope, prevailing winds, and other factors, would the project exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?

Previous Significance Determination: Refer to Response 3.20(a).

Project‐Specific Analysis: Refer to Response 3.20(a). No impact would occur.

Significance Determination: No substantial increase in the level of impact from previous analysis.

c) Would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?

Previous Significance Determination: Refer to Response 3.20(a).

Project‐Specific Analysis: Refer to Response 3.20(a). No impact would occur.

Significance Determination: No substantial increase in the level of impact from previous analysis.

d) Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?

Previous Significance Determination: Refer to Response 3.20(a).

Project‐Specific Analysis: Refer to Response 3.20(a). No impact would occur.

Significance Determination: No substantial increase in the level of impact from previous analysis.

3.20.1 MITIGATION PROGRAM

Mitigation Measures from SEIR No. 332

SEIR No. 332 does not include mitigation measures for wildfire.

16 California Department of Forestry and Fire Resources, Very High Fire Hazard Severity Zones in LRA Map for Anaheim, October 2011.

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
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Final | March 2022 3-107 Environmental Analysis
Mitigation Measures from SEIR No. 339

SEIR No. 339 does not include mitigation measures for wildfire.

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Final | March 2022 3-109 Environmental Analysis

3.21 MANDATORY FINDINGS OF SIGNIFICANCE

Would the project:

New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce
Significant
Impact
No
Substantial
Change
from
Previous
Analysis
a. Does the project have the potential to substantially degrade the quality of the environment, substantially
reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self -sustaining levels, threaten to eliminate a plant or animal
community, substantially reduce the number or restrict
the range of a rare or endangered plant or animal or
eliminate important examples of the major periods of
California history or prehistory?

b. Does the project have impacts that are individually
limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a
project are considerable when viewed in connection
with the effects of past projects, the effects of other current projects, and the effects of probable future
projects)?

c. Does the project have environmental effects which will cause substantial adverse effects on human beings,
either directly or indirectly?


a) Does the project have the potent ial to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self‐sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory?

No substantial change from previous analysis. As concluded in Section 3.1 through 3.20 of this Addendum, Project implementation would not de grade the qual ity of the envir onment. Project implementation would not substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self -sustaining levels, or reduce the number or restrict the range of a rare or endangered plant or animal beyond the level of impact as previously analyzed in SEIR No. 339; refer to Section 3. 5, Cultural Resources . As indicated in Section 3.5 , the Project Site (a segment of Orangewood Avenue and the Santa Ana River reorganization area) does not contain important examples of the major periods of California history or prehistory. In addition, no additional information of substantial importance concerning these issue areas has been discovered since SEIR No. 339 certification. Therefore, Project implementation would not result in any new impacts or increase the severity of impacts previously identified by SEIR No. 339, and no substantial change would occur.

b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)?

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
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Final | March 2022 3-110 Environmental Analysis
No subs tantial change from previous analysis. SEIR No. 339 concluded that implementation of the PTMLUP would result in significant and unavoidable cumulative impacts to air quality, and a Statement of Overriding Considerations was adopted by the City of Anaheim. The Project involves a limited footprint that generally aligns with existing Orangewood Avenue roadway right -of-way and the Santa Ana River reorganization area. Based on the Project Site’s disturbed conditions, it is not anticipated that Project implementation would result in any new c umulative impacts or increase the severity of a previously identified significant cumulative impact as previously identified by SEIR No. 339, and no substantial change would occur.

c) Does the project have environmental effects which will cause subs tantial adverse effects on human beings, either directly or indirectly?

No substantial change from previous analysis. The Project would not result in environmental effects which would cause a direct or indirect effect on human beings, following conformance with existing SEIR No. 339 mitigation measures and the established regulatory framework . Based on the nature of the proposed improvements, Project implementation would not result in any new impacts or increase the severity of previously identified significant impacts as previously identified by SEIR No. 339, and no substantial change would occur.

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
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Final | March 2022 4-1 References

4.0 REFERENCES

California Department of Conservation, Agricultural Preserves 2004 (Williamson Act Parcels Orange County, California), 2004.

California Department of Conservation, Farmland Mapping and Monitoring Program, Orange County Important Farmland 2012, January 2015.

California Department of Conservation, Seismic Hazard Zone Map for the Anaheim Quadrangle, Released April 15, 1998.

California Department of Forestry and Fire Resources, Very High Fire Hazard Severity Zones in LRA Map for Anaheim, October 2011.

California Department of Transportation Website, California Scenic Highway Mapping System , http://www.dot.ca.gov/hq/LandArch/16_livability/scenic_highways/index.htm, Accessed October 11, 2017.

California Department of Transportation, Caltrans Technical Noise Supplement to the Traffic Noise Analysis Protocol, September 2013.

California Governor’s Office of Planning and Research, Technical Advisory on Evaluating Transportation Impacts in CEQA, dated April 16, 2018.

CalRecycle Website, Disposal Reporting System (DRS): Jurisdiction Disposal and Alternative Daily Cover (ADC) Tons by Facility ,
https://www2.calrecycle.ca.gov/LGCentral/DisposalReporting/Destination/Disposal ByFacility, Accessed August 28, 2019.

City of Anaheim, Anaheim General Plan, 2004.

City of Anaheim, Anaheim General Plan and Zoning Code Update Environmental Impact Report No. 330 (SCH #2003041105), 2004.

City of Anaheim, Anaheim Municipal Code, current through August 2017.

City of Anaheim, Hazard Mitigation Plan, 2015.

City of Anaheim, The Platinum Triangle Draft Subsequent Environmental Impact Report No. 332 (SCH No. 2004121045), May 2005.

City of Anaheim, The Platinum Triangle Final Subsequent Environmental Impact Report No. 332 (SCH No. 2004121045), August 2005.

City of Anaheim, The Platinum Triangle Master Land Use Plan, Updated 2014.

City of Anaheim, The Revised Platinum Triangle Expansion Project Draft Subsequent Environmental Impact Report No. 339 (SCH #2004121045), 2010.

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
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Final | March 2022 4-2 References

City of Anaheim, The Revised Platinum Triangle Expansion Project Final Subsequent Environmental Impact Report No. 339 (SCH #2004121045), 2010.

City of Orange, Multi-Hazard Functional Plan, n.d.

City of Orange, City of Orange General Plan Program Environmental Impact Report (SCH #2006031117) , 2010.

City of Orange, Orange General Plan, 2010.

City of Orange, Orange Municipal Code, current through May 2017.

Federal Emergency Management Agency Website, FEMA Zone Definitions , http://www.floodadvocate.com/fema-zone-
definitions/?gclid=CjwKEAjw4vzKBRCt9Zmg8f2blgESJADN5fDgTspDzPxBH5dp9mar2pUN_suNf1cjN8 Rj8Vko6HTHHxoCzGz w_wcB, Accessed October 4, 2017.

Federal Highway Administration, Roadway Construction Noise Model (FHWA-HEP-05-054), January 2006.

LSA Associates, Inc., Platinum Center in City of Anaheim Traffic Study, August 2016.

Michael Baker International, Jurisdictional Delineation for the Orangewood Avenue Bridge Widening Over Santa Ana River in the City of Orange, California, January 22, 2018.

Michael Baker International, Phase I Environmental Site Assessment for the Orangewood Avenue Improvements Project located in the Cities of Anaheim and Orange, California, October 2017.

Michael Baker International, Results of a Biological Resources Assessment for the Orangewood Avenue Bridge Widening Over Santa Ana River in the City of Orange, California, September 28, 2017.

Michael Baker International, Traffic Analysis for the SR-57 Ramps at Orangewood Avenue Memorandum, June 2017.

Orange County Transportation Authority, 2015 Orange County Congestion Management Program, Figure 4: CMP Level of Service Chart, November 2015.

Orange County Transportation Authority, Draft 2017 Orange County Congestion Management Program, Figure 4: 2017 CMP Level of Service Chart, September 2017.

Solid Waste Information System (SWIS), Integrated Waste Management Board, https://www2.calrecycle.ca.gov/swfacilities/Directory/19-AA-0013/Index, Accessed August 28, 2019.

South Coast Air Quality Management District, Final 2016 Air Quality Management Plan, March 2017.

Southern California Association of Governments, 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy, April 2016.

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Orangewood Avenue Improvements

Final | March 2022 5-1 Preparers and Contributors

5.0 PREPARERS AND CONTRIBUTORS

City of Anaheim (Lead Agency)
Planning and Building Department, Planning Services Division 200 South Anaheim Boulevard
Anaheim, California 92805

Andy Uk, Associate Planner
Charles M. Guiam, Planner
Carlos Castellanos, City Engineer
Cesar Carrillo, Principal Civil Engineer

Michael Baker International (Environmental Consultant)
5 Hutton Centre Drive, Suite 500
Santa Ana, California 92707

Alan Ashimine, Project Manager
Kristen Bogue, Senior Environmental Analyst/Hazardous Materials Specialist Frances Yau, Environmental Analyst
Alicia Gonzalez, Environmental Analyst
Winnie Woo, Environmental Analyst
Marc Violett, Traffic Engineer
Rich Beck, Regulatory Task Manager
Josephine Lim, Regulatory Analyst
Danielle Regimbal, Air Quality/Greenhouse Gas/Noise Specialist

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Orangewood Avenue Improvements

Final | March 2022 5-2 Preparers and Contributors
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SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Orangewood Avenue Improvements

Final | March 2022 6-1 Acronyms and Abbreviations

6.0 ACRONYMS AND ABBREVIATIONS

Acronym/Abbreviation Definition
ADA Americans with Disabilities Act
ADL Aerially-deposited lead
AFD Anaheim Fire Department
ALUC Airport Land Use Commission
APD Anaheim Police Department
APN Assessor parcel number
AQMP Air Quality Management Plan
ATAM Anaheim Traffic Analysis Model
BAAQMD Bay Area Air Quality Management District
BMP best management practice
CAAQS California Ambient Air Quality Standards
CalEEMod California Emissions Estimator Model
Caltrans California Department of Transportation
CARB California Air Resources Board
CAT Climate Action Team
CBC California Building Code
CCR California Code of Regulations
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
CH4 Methane
City City of Anaheim
CMP Congestion Management Plan
CNEL community noise equivalent level
CO carbon monoxide
CO2 carbon dioxide
CO2E carbon dioxide equivalent
DAMP Drainage Area Management Plan
dBA A-weighted deci bel
DMA drainage management areas
EIR environmental impact report
ESA Environmental Site Assessment
FEMA Federal Emergency Management Agency
GHG greenhouse gas
GPF gallons per flush
gsf gross square feet
GWP Global warming potential

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Orangewood Avenue Improvements

Final | March 2022 6-2 Acronyms and Abbreviations
Acronym/Abbreviation Definition
HCP Habitat Conservation Plan
HVAC heating, ventilation, and air conditioning
I-5 Interstate 5
ICU Intersection Capacity Utilization
lbs/day pounds per day
LED Li ght-em itting diode
LOS level of service
LST localized significance threshold
LUST leaking underground storage tank
MBTA Migratory Bird Treaty Act
MLD most likely descendent
MM Mitigation Measure
MMRP Mitigation Monitoring and Reporting Program
MPAH Master Plan of Arterial Highways
mph miles per hour
MRZ Mineral Resource Zone
msl mean sea level
MT metric ton
MMT million metric tons
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NCCP Natural Community Conservation Plan
NO2 nitrogen dioxide
NOx oxides of nitrogen
NPDES National Pollutant Discharge Elimination System
O3 ozone
OCSD Orange County Sanitation District
OCTA Orange County Transportation Authority
OCWD Orange County Water District
PEC Potential environmental condition
PM10 particulate matter less than or equal to 10 micrometers in diameter PM2.5 particulate matter less than or equal to 2.5 microns in diameter ppm parts per million
PRC Public Resources Code
PTIP Platinum Triangle Implementation Plan
PTMLUP Platinum Triangle Master Land Use Plan
PTMU Platinum Triangle Mixed Use
REC recognized environmental condition

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Orangewood Avenue Improvements

Final | March 2022 6-3 Acronyms and Abbreviations
Acronym/Abbreviation Definition
RTP Regional Transportation Plan
SARI Santa Ana River Interceptor
SCAB South Coast Air Basin
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCS Sustainable Communities Strategy
SEIR Subsequent Environmental Impact Report
SEMS Standardized Emergency Management System
sf square feet
SR State Route
SRA Source Receptor Area
SWPPP Stormwater Pollution Prevention Plan
UCI University of California, Irvine
USFWS U.S. Fish and Wildlife Service
UST underground storage tank
VAV Variable air volume
VPH Vehicles per hour
VOCs volatile organic compounds
WQMP Water Quality Management Plan

SUBSEQUENT ENVIRONMENTAL IMPACT REPORT ADDENDUM
Orangewood Avenue Improvements

Final | March 2022 6-4 Acronyms and Abbreviations
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APPENDIX A
Biological Resources Assessment

September 28, 2017
Rafael Contreras
City of Anaheim
200 S Anaheim Boulevard, Suite 276
Anaheim, CA 92805

SUBJECT: Results of a Biological Resource s Assessment for the Orangewood Avenue Bridge Widening Over Santa Ana River in the City of Orange, California.

Dear Mr. Contreras:

Michael Baker International (Michael Baker) has prepared this letter report to document the results of a biological resources site assessment for the Orangewood Avenue Bridge Widening Over Santa Ana River.

Methods
Prior to the site visit, Michael Baker conducted a 4-quadrangle records search of the California Department of Fish and Wildlife (CDFW) California Natural Diversity Database (CNDDB) RareFind 5 and the California Native Plant Society (CNPS) Online Inventory of Rare and Endangered Plants. Other sources included the U.S. Fish and Wildlife Service (USFWS) Environmental Conservation Online System (ECOS) Critical Habitat online mapper , U.S. Department of Agriculture /Natural Resources Conservation Service (USDA/NRCS) Web Soil Survey , Federal Emergency Management Agency (FEMA) 100 -Year Flood Zones, and USFWS National Wetlands Inventory (NWI) maps online.

On September 13, 2017, between the hours of 7:45 a.m. and 9:00 a .m., Michael Baker biologists Linda Nguyen and Stephen Anderson conducted a biological resources site assessment. Weather conditions consisted of overcast skies, and a temperature ranging between approximately 65 to 70 degrees Fahrenheit. The survey was conducted by walking around the project site documenting all plant and wildlife species observed (Attachment 1) and photographing existing site conditions (Exhibit 4). The area of study included 100 feet upstream and downstream of the Orangewood Avenue bridge.

Results
The project area consists of the Santa Ana River that conveys perennial flows from north to south. To the east of the Santa Ana River, the State Route 57 (SR-57) runs north and south. East and southwest of the project boundary consists of existing residential and commercial developments. The Angel Stadium property is located directly west of the Santa Ana River.

Soils mapped by the USDA/NRCS within the pr oject bo undary consist of Hueneme fine sandy loam, drained (158); Metz loamy sand, moderately fine substratum (164), and Riverwash (191).

The Santa Ana River is sand-bottomed, regularly maintained, and was void of vegetation communities .

Minimal vegetation was present along the sediment of the river bed including common knotweed (Persicaria lapathifolia), castor bean (Ricinus communis), rough co cklebur (Xanthium strumarium), and white sweetclover (Melilotus albus). The disturbed banks primarily contained sugar bush (Rhus ovata),

California buckwheat (Eriogonum fasciculatum), Hottentot fig (Carpobrotus edulis), Russian thistle (Salsola tragus), and bush sunflower (Encelia californica). A complete list of plant s and wildlife species observed during the survey is provided in Attachment 1.

The NWI identifies the Santa Ana River as Lake. The FEMA maps indicate that the Santa Ana River is located in Zone A , areas subject to inundation by the 1 -percent-annual-chance flood event , with the surrounding areas within the project site designated as Zone X, an area with reduced risk due to leve e.

The Santa Ana River was observed with no surface flows at the time of the visit. The ordinary high water mark (OHWM), which is used to identify the non-wetland waters of the U.S. limits subject to jurisdiction of the U.S. Army Corps of Engineers (Corps) and regional Water Quality Control Board (Regional Board) pursuant to the Federal Clean Water Act (CWA) Section s 404 and 401, respectively, varied between approximately 255 to 265 feet wide. Streambed and active banks subject to CDFW jurisdiction pursuant to the California Fish and Game Code Sections 1600 et seq. averaged approximately 300 feet wide to the top of banks.

No special-status plant or wildlife species were observed on-site. Based on the records search, a total of four (4) special-status plant species and eighteen (18) special-status wildlife species have been recorded within the vicinity of the project by the CNDDB and CNPS online inventory. Most of these species have a low potential or are not expected to occur on-site due to a lack of habitat suitable to support them. There is a potential for various special-status species to occur within the project site, including, but not limited to, American peregrine falcon (Falco peregrinus anatum ), coast horned lizard (Phrynosoma blainvillii ), whiptails (Aspidoscelis spp.), Swainson's hawk (Buteo swainsoni), and bats (Order Chiroptera). Of the twenty-two (22) species, the records search includes tw o (2) wildlife species that are listed under the Federal Endangered Species Act and/or the California Endangered Species Act warranting protection from take. Due to the disturbed nature of the site and a lack of suitable habitat, none of the listed species known to occur within the vicinity of the project area are expected to occur on-site. Further, the project area is not located within mapped USFWS-designated Critical Habitat.

Recommendations
It is highly recommended that the delineation results be forwarded to each of the regulatory agencies for their concurrence. The concurrence/receipt would be valid up to five years and would solidify findings noted within this report.

Please contact me at (949) 472-3436 or at [email protected] with any questions you may have regarding this project.

Sincerely,

Linda Nguyen
Biologist/Regulatory Analyst
Natural Resources/Regulatory Permitting
Attachment 1: Plant and Wildlife Species Observed List

Orangewood Avenue Improvements from the Santa Ana River to the East of SR-57 Project Biological Resources Assessment
Attachment 1: Plant and Wildlife Species Observed List
Scientific Name* Common Name
Plants
Carpobrotus edulis Hottentot fig
Encelia californica bush sunflower
Eriogonum fasciculatum California buckwheat
Melilotus albus white sweetclover
Persicaria ssp. Persicaria
Rhus ovata sugarbush
Ricinus communis castor bean
Salsola tragus Russian thistle
Xanthium strumarium Rough cocklebur
Birds
Buteo jamaicensis red-tailed hawk
Columba livia rock dove
Corvus brachyrhynchos American crow

APPENDIX B
Jurisdictional Delineation

Jan
uary 22, 2018

Rafael Contreras
City of Anaheim
200 S Anaheim Boulevard, Suite 276
Anaheim, CA 92805

Subject: Jurisdictional Delineation for the Orangewood Avenue Bridge Widening Over Santa Ana River in the City of Orange, California.

Dear Mr. Contreras:

Michael Baker International (Michael Baker) has prepared this letter report to document the results of a jurisdictional delineation that has been prepared for the City of Anaheim, in order to delineate the U.S. Army Corps of Engineers’ (Corps), San Diego Regional Water Quality Control Board’s (Regional Board), and California Department of Fish and Wildlife’s (CDFW) jurisdictional authority located within the Orangewood Avenue Bridge Widening Over Santa Ana River (project site). The field work for this delineation was conducted on September 13, 2017.

Project Description
The
City proposes to widen Orangewood Avenue from a four‐lane roadway to a six‐lane divided facility to provide expanded vehicle, bicycle, and pedestrian access. The project would incorporate an additional through lane in each direction of travel through the project site boundaries. To widen the roadway, the project would widen the existing Orangewood Avenue bridge structure over the Santa Ana River. Bridge widening improvements would involve widening the bridge an additional 30-35 feet to accommodate the proposed six travel lanes and associated sidewalk. Five (5) existing bents will be lengthened for the widening. The bents are situated along the River bottom. The proposed total bridge length would be 348 feet, six inches. In addition, to accommodate the proposed roadway widening, improvements within existing Caltrans right -of- way (associated with the SR -57/Orangewood Avenue interchange) would include a Caltrans - standard type 1 retaining wall up to eight feet in height along the nort hern side of Orangewood Avenue.

Jurisdictional impacts associated with bridge widening over the S anta Ana River would result in

0.03-acre of permanent impacts and 1.12- acre of temporary impacts to CDFW unvegetated streambed.

Site
Conditions
San
ta Ana River traverses under the Orangewood Avenue Bridge in north to south direction. The U.S. Army Corps of Engineers (Corps) Ordinary High Water Mark ( OHWM) ranged from 255 to 265 feet in width and the California Department of Fish and Wildlife ( CDFW) jurisdictional streambed ranged from approximately 300 feet in width. Water flow was not noted within the channel during the site visit. No wetland features were noted onsite during the site visit.

Recommendations
Plea
se note that based on a detailed review of the current site conditions and proposed project, our research has indicated that it will be necessary for City of Anaheim to successfully obtain the following permits should construction activities occur within State and Federal jurisdictional areas:

Corps Section 404 Nationwide Permit 14- Linear Transportation Projects, Regional Board Section 401 Water Quality Certification and CDFW 1602 Streambed Alteration Agreement.

Please contact me at (949) 855-3687 or at [email protected] with any questions you may have regarding this project.

Sincerely,

Richard Beck
Regulatory Task Manager
Natural Resources/Regulatory Permitting

APPENDIX C
Phase I Environmental Site Assessment

PHASE I

ENVIRONMENTAL SITE ASSESSMENT

Orangewood Avenue Improvements

Cities of Anaheim and Orange
State of California

Prepared in General Accordance with:

ASTM E 1527-13 Standard Practice for Environmental Site Assessments

For:

City of Anaheim
Public Works Department
200 South Anaheim Boulevard
Anaheim, CA 92805
Attn: Rafael Contreras, P.E.

By:

5 Hutton Centre Drive, Suite 500
Santa Ana, California 92707

October 2017

JN 159416

5 Hutton Centre Drive, Suite 500 | Santa Ana, CA 92707
Office: 949.472.3505 | Fax: 949.837.4122

October 12, 2017 159416

City of Anaheim
Public Works Department
200 South Anaheim Boulevard
Anaheim, CA 92805

SUBJECT: Phase I Environmental Site Assessment for the Orangewood Avenue Improvements Project located in the Cities of Anaheim Orange, California.

Dear Rafael Contreras,

Michael Baker International (Michael Baker), is pleased to submit this Phase I Environmental Site Assessment (ESA) for the above referenced project, herein referenced as the “subject site.” The goal of this Phase I ESA is to identify recognized environmental conditions (RECs) associated with the subject site. This Phase I ESA has been prepared for the sole use of City of Anaheim, for the above-referenced subject site. Neither this Phase I ESA, nor any of the information contained herein, shall be used or relied upon for any purpose by any person or entity other than City of Anaheim.

The Phase I ESA was prepared using methods consistent with the ASTM International (ASTM) E 1527-13 Standard Practice for Environmental Site Assessments, the scope of services, and inherent limitations presented in our proposal. The Phase I ESA is not intended to present specific quantitative information as to the actual presence of hazardous substances on or adjacent to the subject site, but is to identify RECs based on available information.

Should you or your staff have any questions or concerns after reviewing the enclosed report, please do not hesitate to contact me at 949/855-5747.

Sincerely,

Kristen Bogue
Environmental Professional
Planning/Environmental Services

STATEMENT OF ENVIRONMENTAL PROFESSIONAL

I [We] declare that, to the best of my [our] professional knowledge and belief, I[we] meet the definition of Environmental Professional as defined in §312.10 of Title 40, Code of Federal Regulations (CFR) 312 and I[we] have the specific qualifications based on education, training, and experience to assess a property of the nature, hist ory, and setting of the subject property. I[we] have developed and performed all appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312.

___________________________________
Signature of Michael Baker Environmental Professional
Kristen Bogue

Orangewood Avenue Improvements Phase I ESA | i

TABLE OF CONTENTS

Executive Summary .............................................................................................................................. E-1

Section 1.0 Introduction .................................................................................................................. 1-1

1.1 Purpose .............................................................................................................. 1-1

1.2 Detailed Scope of Services .............................................................................. 1-1

1.3 Significant A ssumptions ................................................................................. 1-2

1.4 Limitations, Deviatio ns, and Exceptions ...................................................... 1-2

1.5 User Responsi bilities .................................................................................. 1-3

1.6 Special Terms and Conditions ....................................................................... 1-6

1.7 User Re liance .................................................................................................... 1-6

Section 2.0 User Pr ovided Information ........................................................................................ 2-1

2.1 Previous Documents ........................................................................................ 2-1

2.2 Litigation/Administrative Proceedings ....................................................... 2-2

2.3 Governmental Notices..................................................................................... 2-2

2.4 Environmental Liens ....................................................................................... 2-2

2.5 Activity and Use Limitations ......................................................................... 2-2

2.6 Specialized Knowledge or Experience .......................................................... 2-2

2.7 Commonly Known or Reasonably Ascertainable Information ................. 2-2

2.8 Valuation Reduction for Environmental Issues ........................................... 2-3

2.9 Degree of Obviousness .................................................................................... 2-3

2.10 Reason for Perf orming Phase I ....................................................................... 2-3

Section 3.0 Records Review .................................................................................................... ........ 3-1

3.1 Physical Setting Sources .................................................................................. 3-1

3.2 Standard Environmental Records Sources ................................................... 3-8

3.3 File Record Reviews ...................................................................................... 3-14

3.4 Historical Use Information on the
Subject Site and Adjo ining Properties ......................................................... 3-15

Section 4.0 Site Reconnaissance ............................................................................................... ..... 4-1

4.1 Methodology and Limiting Conditions ........................................................ 4-1

4.2 On-Site Observations ....................................................................................... 4-1

4.3 Off-Site Observations ...................................................................................... 4-6 Table of Contents

Orangewood Avenue Improvements Phase I ESA | ii
Section 5.0 Interviews ........................................................................................................ .............. 5-1

5.1 Property Owner ............................................................................................... 5-1

5.2 Key Site Manag er/Operator ........................................................................... 5-1

5.3 Occup ants .......................................................................................................... 5-1

5.4 Local Governme nt Officials ............................................................................ 5-2

5.5 Other Persons ................................................................................................... 5-2

Section 6.0 Evaluation ...................................................................................................................... 6-1

6.1 Findings and Opinions .................................................................................... 6-1

6.2 Conclu sions ....................................................................................................... 6-6

6.3 Limiting Condit ions/Deviations ................................................................... 6-7

Section 7.0 References ........................................................................................................ ............. 7-1

List of Exhibits

1. Regional Vicinity .............................................................................................. 3-2

2. Site Vi cinity ....................................................................................................... 3-3

3. Subject Site ........................................................................................................ 3-4

4. Overview Map .................................................................................................. 3-9

5. On-Site Photographs ....................................................................................... 4-2

6. Off-Site Photographs ....................................................................................... 4-3

List of Tables
1-1. Groundwater Plume Di mension Assumptions ........................................... 1-2 3-1. Database Summaries ..................................................................................... 3-10 3-2. Identified Regulatory Sites of Concern ....................................................... 3-11 3-3. Historical Uses Summary ............................................................................. 3-18

Appendices
Appendix A: ASTM Terminology
Appendix B: Database Records Searches
Appendix C: Documentation
Appendix D: Qualifications of the Environmental Professional

Orangewood Avenue Improvements Phase I ESA | iii

LIST OF ACRONYMS

ACM Asbestos Containing Materials
APN Assessor’s Parcel Number
AST Aboveground Storage Tank
ATSDR Agency for Toxic Subst ances and Disease Registry AULs Activity and Use Limitations
CERCLIS Comprehensive Environmental Response, Compensation, and Liability Information System (maintained by the Environmental Protection Agency) CFR Code of Federal Regulations
CORRACTS facilities subject to Corrective Action under RCRA CPSC United States Consumer Product Safety Commission
DDD Dichlorodiphenyldichloroethane
DDE Dichlorodiphenyldichloroethylene
DDT Dichlorodiphenyltrichloroethane
DOGGR California Department of Oil, Gas, and Geothermal Resources DTSC Department of Toxic Substances Control
EDR Environmental Data Resources
EPA United States Environmental Protection Agency
EPCRA Emergency Planning and Community Right to Know Act (also known as SARA Title III), 42 U.S.C. §§11001-11050 et seq.)
ERNS emergency response notification system
ESA Environmental Site Assessment
FOIA U.S. Freedom of Information Act (5 U.S.C. §552 as amended by Public Law No. 104-231, 110 Stat.)
FR Federal Register
HREC Historical Recognized Environmental Condition
ICs Institutional Controls
LBP Lead Based Paints
LUFT Leaking Underground Fuel Tank
LUST Leaking Underground Storage Tank
MSDS Material Safety Data Sheet
msl Mean sea level
NCP National Contingency Plan
NFRAP former CERCLIS sites where no further remedial action is planned under CERCLA NPDES National Pollutant Discharge Elimination System
NPL National Priorities List
Acronyms

Orangewood Avenue Improvements Phase I ESA | iv
PCBs Polychlorinated Biphenyls
REC Recognized Environmental Condition
RCRA Resource Conservation and Recovery Act (as amended, 42 U.S.C. §§6901 et seq.) RWQCB Regional Water Quality Control Board
SBBM San Bernardino Base and Meridian
SCS Soil Conservation Service
TPH Total Petroleum Hydrocarbons
TRI Toxics Release Inventory
TSDF hazardous waste treatment, storage, or disposal facility USDA United States Department of Agriculture
USGS United States Geological Survey
UST Underground Storage Tank

Orangewood Avenue Improvements Phase I ESA | E-1

EXECUTIVE SUMMARY

Michael Baker has performed a Phase I Environmental Site Assessment (Phase I ESA) in conformance with the scope and limitations of ASTM International (ASTM) E 1527-13 Standard Practice of the Orangewood Avenue Improvements, located in the cities of Anaheim and Orange, Orange County, California, the subject site. Any exceptions to, or deletions from, this practice are described in Section 1.0, Introduction, of this Phase I ESA. This Phase I ESA has revealed the following evidence of recognized environmental conditions (RECs) in connection with the subject site:

 Aerially Deposited Lead: Based on historic al aerial photographs and United States Geological Survey (USGS) topographic ma ps, SR-57 was constructed in 1977. The potential for lead contamination to exist wi thin exposed soils on-site due to aerially deposited lead is likely. It is Michael Baker’s opinion that there is a REC on the subject site as a result of aerially deposited lead.

 Groundwater Contamination: The adjacent property located at 2023 Collins Street (approximately 2,420 feet up gradient of the subject site) was found to have groundwater contamination extending to a maximum distance of 6,500 feet down gradient, which includes the subject site and areas of propose right-of-way (ROW) acquisition. As such, it is the opinion of Michael Baker that a REC has resulted via groundwater from the adjacent regulatory property located at 2023 Collins Street. It is acknowledged that groundwater is anticipated to be greater than 80 feet below ground surface.

Section 6.1, Findings and Opinions , documents Michael Baker’s findings and opinions as to whether or not a REC (or Conditional Recognized Environmental Condition [CREC]) is present at the subject site.

Orangewood Avenue Improvements Phase I ESA | 1-1

SECTION 1.0

INTRODUCTION

1.1 PURPOSE

The purpose of conducting this Phase I Enviro nmental Site Assessment (ESA) is to identify Recognized Environmental Conditions (RECs) as defined by the ASTM International (ASTM) E 1527-13 Standard Practice for Environmental Site Assessments (Standard Practice). The ASTM E 1527-13 Standard Practice defines the term REC as “the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to any release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment. De minimis conditions are not RECs.”

This Phase I ESA was conducted in accordance with the ASTM E 1527-13 Standard Practice and satisfies the requirements of 40 Code of Federal Regulations (CFR) Part 312 titled Standards and Practices for All Appropriate Inquiries, as required under Section 101(35)(B)(ii) and (iii) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The purpose of conducting an All Appropriate Inqu iries (AAI) investigation into the previous ownership and uses of a property is to meet the provisions necessary for the innocent landowner, contiguous property owner, or bona fide prospective purchaser to qualify for certain landowner liability protections under CERCLA. To assist in understanding the terminology contained in this Phase I ESA, a glossary of terms associat ed with the ASTM E 1527-13 Standard Practice is provided in Appendix A, ASTM Terminology.

1.2 DETAILED SCOPE OF SERVICES

This scope of work follows the ASTM E 1527-13 Standard Practice. The ASTM E 1527-13 Standard Practice outlines a procedure for completing Phase I ESAs that includes review of Federal, tribal, State, and local government records; site re connaissance; interviews with current owners, operators, occupants, and government officials; and report preparation. This practice does not include any testing or sampling of materials (for example, soil, water, air, building materials, etc.).

This Phase I ESA is not intended to provide specif ic qualitative or quantitative information as to the actual presence of hazardous substances at the subject site, but is to merely identify the potential presence based on available information.

Section 1.0 | Introduction

Orangewood Avenue Improvements Phase I ESA | 1-2

1.3 SIGNIFICANT ASSUMPTIONS

Unless stated otherwise in this Phase I ESA, Michael Baker assumes that groundwater flow follows the topography of the subject site.

In lieu of reasonably available public information pertaining to groundwater contamination, Michael Baker assumes that groundwate r plume dimensions are within the 90 th percentile of
plumes determined by research conducted as part of ASTM E 2600-10 Standard Guide for Vapor Encroachment Screening on Property Involved in real Estate Transactions, which described in detail in Table 1-1, Groundwater Plume Dimension Assumptions.

Table 1-1
Groundwater Plume Dimension Assumptions

Chemical Contamination Length of Plume Up-
Gradient From Source
Length of Plume Down-
Gradient from Source
Maximum Width of Plume
From Source
Chemical of Concern 100 feet 1,760 feet 365 feet
Petroleum Hydrocarbon Chemical of Concern
With Free Product 100 feet 528 feet 165 feet
Dissolved 100 feet 528 feet 95 feet
Notes: These dimension assumptions are based on research conducted as part of ASTM E 2600-10 Standard Guide for Vapor Encroachment Screening on Property Involved in real Estate Transactions, which has determined that 90 percent of plumes are these dimensions or less.

Source: Anthony J. Buonicore, Methodology for Identifying the Area of Concern Around a Property Potentially Impacted by Vapor Migration from Nearby Contaminated Sources, Paper 2011-A-301-AWMA, June 2011.

1.4 LIMITATIONS, DEVIATIONS, AND EXCEPTIONS

No interviews with current/past property owners or local government officials were conducted.

Based on available information reviewed as part of this Phase I ESA, past and current on-site uses appeared to historically consist of the Santa Ana River, past agricultural uses, and transportation uses. No evidence to suggest other uses was noted. Based on the historical documentation reviewed, it is Michael Baker’s opinion that these interviews would not increase the knowledge of the Environmental Professional such that the conclusions of this Phase I ESA would change.

Thus, it is the opinion of Michael Baker that this deviation is not a significant data gap.

No additional scope items, or items outside of the scope of a Phase I ESA E 1527-13 Standard Practice, were conducted as part of this Phase I ESA.

Section 1.0 | Introduction

Orangewood Avenue Improvements Phase I ESA | 1-3

1.5 USER RESPONSIBILITIES

This Phase I ESA does not satisfy continuing obligations under CERCLA liability protections provided for innocent landowners, bona fide pr ospective purchasers, and contiguous property owners, which includes, but is not limited to, duti es required after property acquisition (i.e., compliance with land use restrictions and instit utional controls, undertaking “reasonable steps” with respect to hazardous substances releases , compliance with other obligations such as reporting obligations and information requests, etc.).

ASTM E 1527-13 Standard Practice defines the user as “the party seeking to use Practice E 1527 to complete an environmental site assessment of the property. A user may include, without limitation, a potential purchaser of property, a potential tenant of property, an owner of property, a lender, or a property manager.” The purpose of this section is to describe tasks to be performed by the user that will help identify the possib ility of recognized enviro nmental conditions in connection with the subject site. These tasks do not require the technical expertise of an environmental professional and are not required to be performed by environmental professional performing a Phase I ESA. It should be noted that the following tasks are required, by the user of this Phase I ESA, to satisfy the requirements of conducting all appropriate inquiries.

1.5.1 REVIEW TITLE AND JUDICIAL RECORDS FOR

ENVIRONMENTAL LIENS OR ACTIVITY AND USE

LIMITATIONS (AULS)

To meet the requirements of 40 CFR 312.20 and 312.25, a search for the existence of environmental liens and AULs that are filed or recorded against the property must be conducted. Environmental liens and AULs are legally distinct instruments and have very different purposes and both can commonly be found within recorded land title records (e.g., County Recorder/Registry of Deeds).

The types of title reports that may disclose environmental liens and AULs include Preliminary Title Reports, Title Commitments, Condition of Titl e, and Title Abstracts. Chain of title reports will not normally disclose environmental liens or AULs. Environmental liens and AULs that are imposed by judicial authorities may be recorded or filed in judicial records only. In jurisdictions where environmental liens or AULs are only recorded or filed in judicial records, the judicial records must be searched for environmental liens and AULs. Any environmental liens and AULs known to the user should be reported to the environmental professional conducting a Phase I Environmental Site Assessment. Unless added by a change in the scope of work to be performed by the environmental professional (refer to Section 1.4, Limitations, Deviations, and Exceptions), this practice does not impose on the environmental professional the responsibility to undertake a review of recorded land title records and judicial records for environmental liens or activity and use limitations. The user should either (1) en gage a title company or title professional to Section 1.0 | Introduction

Orangewood Avenue Improvements Phase I ESA | 1-4
undertake a review of reasonably ascertainable recorded land title records and lien records for environmental liens or activity and use limitations currently recorded against or relating to the property, or (2) negotiate such an engagement of a title company or titl e professional as an addition to the scope of work to be performed by the environmental professional.

1.5.1.1 Reasonably Ascertainable Title and Judicial Records for Environmental Liens and Activity and Use Limitations

Environmental liens and AULs that are recorded or filed in any place other than recorded land title records are not considered to be reasonably ascertainable unless applicable Federal, tribal, State, or local statues, or regulations specify a place other than recorded land title records for recording or filing of environmental liens and AULs.

1.5.2 SPECIALIZED KNOWLEDGE OR EXPERIENCE OF THE USER

Users must take into account their specialized knowledge to identify conditions indicative of releases or threatened releases. If the user has any specialized knowledge or experience that is material to RECs in connection with the property, the user should communicate any information based on such specialized knowledge or experience to the environmental professional. The user should do so before the environmental professional conducts the site reconnaissance.

1.5.3 ACTUAL KNOWLE DGE OF THE USER

If the user has actual knowledge of any envi ronmental lien or AULs encumbering the property or in connection with the property, the user should communicate such information to the environmental professional. The user should do so before the environmental professional conducts the site reconnaissance.

1.5.4 REASON FOR SIGNIFICANTLY LOWER PURCHASE PRICE

In a transaction involving the purchase of a parc el of commercial real estate, the user shall consider the relationship of the purchase price of the property to the fair market value of the property if the property was not affected by hazardous substances or pe troleum products. The user should try to identify an explanation for a lower price which does not reasonably reflect fair market value if the property were not contaminated, and make a written record of such explanation. Among the factors to consider will be the information that becomes known to the user pursuant to the Phase I ESA. The ASTM E 1527-13 Standard Practice does not require that a real estate appraisal be obtained in order to ascertain fair market value of the property. The user should inform the environmental professional if the user believes that the purchase price of the Section 1.0 | Introduction

Orangewood Avenue Improvements Phase I ESA | 1-5
property is lower than the fair market value due to contamination. The user is not required to disclose the purchase price to the environmental professional.

1.5.5 COMMONLY KNOWN OR RE ASONABLY ASCERTAINABLE

INFORMATION

Commonly known or reasonably ascertainable information within the local community about the property must be taken into account by the user. If the user is aware of any commonly known or reasonably ascertainable information within th e local community about the property that is material to recognized environmental conditions in connection with the property, the user should communicate such information to the environmental professional. The user should do so before the environmental professional conducts the site reconnaissance. The user must gather such information to the extent necessary to identify conditions indicative of releases or threatened releases of hazardous substances or petroleum products.

1.5.6 DEGREE OF OBVIOUSNESS

The user must consider the degree of obviousness of the presence or likely presence of releases or threatened releases at the property and the abilit y to detect releases or threatened releases by appropriate investigation including the information collected under the following sections within this Phase I ESA:

 Section 1.5.1, Review Title and Judicial Records for Environmental Liens and Activity and Use Limitations (AULs);
 Section 1.5.2, Specialized Knowledge or Experience of the User;  Section 1.5.4, Reason for Significantly Lower Purchase Price;  Section 1.5.5, Commonly Known or Reasonably Ascertainable Information;  Section 3.2, Standard Environmental Records Sources;
 Section 3.4, Historical Use Information on the Subject Site and Adjoining Properties;  Section 4.0, Site Reconnaissance; and
 Section 5.0, Interviews.

1.5.7 OTHER

Either the user shall make know n to the environmental professional the reason why the user wants to have the Phase I ESA performed or, if the user does not identify the purpose of the Phase I ESA, the environmental professional shall assume the purpose is to qualify for an LLP to CERCLA liability and state this in the report.

Section 1.0 | Introduction

Orangewood Avenue Improvements Phase I ESA | 1-6

1.6 SPECIAL TERMS AND CONDITIONS

No special terms and conditions were identified for this scope of work.

1.7 USER RELIANCE

The information and opinions rendered in this Phase I ESA are exclusively for use by the City of Anaheim. Michael Baker will not distribute or publish this report without the consent of the City of Anaheim, except as required by law or court order. The information and opinions expressed in this Phase I ESA are given in response to Mi chael Baker’s scope of services and limitations indicated above, and should be considered and implemented only in light of the scope of services and limitations. The services provided by Mic hael Baker in completing this Phase I ESA were consistent with normal standards of the profession. No warranty, expressed or implied, is made.

Orangewood Avenue Improvements Phase I ESA | 2-1

SECTION 2.0

USER PROVIDED INFORMATION

Per ASTM E 1527-13, the user of the Phase I ESA has an obligation to answer all questions posed, in good faith, to the extent of his or her actual knowledge or to designate a key site manager to do so. If answers to questions are unknown or partially unknown to the user or such key site manager, this section shall not thereby be deemed incomplete.

The City of Anaheim is the user of this Ph ase I ESA and has provided Michael Baker with information regarding the proposed project (bridge/roadway improvements) for the subject site.

The City has requested this Phase I ESA for the purpose of due diligence for the proposed Orangewood Avenue Improvements project. Ot her information/documentation provided by the City is also referenced throughout this Phase I ESA, as applicable.

2.1 PREVIOUS DOCUMENTS

The user did not provide any previous document s, including but not limited to the following, during the course of this Phase I ESA:

 Environmental site assessments;
 Environmental compliance audit reports;
 Environmental permits;
 Registrations for underground and aboveground storage tanks;  Material safety data sheets;
 Community right-to-known plan;
 Safety plans; preparedness and prevention plans; spill prevention, countermeasure, and control plans; facility response plans; etc.;
 Reports regarding hydrogeologic conditions on the property or surrounding area;  Notices or other correspondence from any government agency relating to past or current violations of environmental laws with respect to the property or relating to environmental liens encumbering the property;
 Hazardous waste generator notices or reports;
 Geotechnical studies;
 Risk assessments; and
 Recorded AULs.

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Orangewood Avenue Improvements Phase I ESA | 2-2

2.2 LITIGATION/ADMINISTRATIVE PROCEEDINGS

The user did not identify any information pertaining to any pending, threatened, or past litigation and/or administrative proceedings relevant to hazardous substances or petroleum products in, on, or from the property during the course of this Phase I ESA.

2.3 GOVERNMENTAL NOTICES

The user did not identify any information pertaining to any notices from any governmental entity regarding any possible violation of environmental laws or possible liability relating to hazardous substances or petroleum products during the course of this Phase I ESA.

2.4 ENVIRONMENTAL LIENS

The user did not provide any environmental lien in formation during the course of this Phase I ESA.

2.5 ACTIVITY AND USE LIMITATIONS

The user did not provide any activity and use lim itation information during the course of this Phase I ESA.

2.6 SPECIALIZED KNOWLEDGE OR EXPERIENCE

The user did not identify any specialized knowle dge or experience related to the subject site during the course of this Phase I ESA.

2.7 COMMONLY KNOWN OR REASONABLY

ASCERTAINABLE INFORMATION

The user did not identify any commonly known or reasonably ascertainable information during the course of this Phase I ESA.

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Orangewood Avenue Improvements Phase I ESA | 2-3

2.8 VALUATION REDUCTION FOR

ENVIRONMENTAL ISSUES

As the project does not involve purchase of private property, no valuation reduction was reported.

2.9 DEGREE OF OBVIOUSNESS

The user did not report any obvious indicators that point to the presence or likely presence of releases at the property during the course of this Phase I ESA.

2.10 REASON FOR PERFORMING PHASE I

This Phase I ESA has been requested by the City of Anaheim for the purpose of environmental compliance documentation for the proposed Orangewood Avenue Improvements project.

Orangewood Avenue Improvements Phase I ESA | 3-1

SECTION 3.0

RECORDS REVIEW

3.1 PHYSICAL SETTING SOURCES

Physical setting sources typically provide information regarding geologic, hydrogeological, hydrologic, or topographic characteristics of a property. The following information is primarily based on the review of the United States Geological Survey (USGS) Anaheim, California Quadrangle (dated 2015), and a site inspection conducted by Michael Baker on September 13, 2017. Other miscellaneous resources utilized within this section and throughout the Phase I ESA are referenced in Section 7.0, References.

3.1.1 SUBJECT SITE DESCRIPTION

3.1.1.1 Location

The subject site is situated at, and to the west of, the State Route 57 (SR-57)/Orangewood Avenue interchange, in the cities of Anaheim and Orange, County of Orange, California (Section 25, Township 4 South [T.4S], Range 10 West [R.10W ], San Bernardino Base and Meridian [SBBM]).

Regionally the site is located approximately 0.63 mile east of Interstate 5 (I-5) and approximately

1.14 miles north of State Route 22 (SR-22). Refer to Exhibit 1, Regional Vicinity, and Exhibit 2, Site Vicinity.

3.1.1.2 Current Use(s) of the Subject Site

The subject site consists of roadway and Orange County Flood Control District (OCFCD) right- of-way (ROW); refer to Exhibit 3, Subject Site.

3.1.1.3 Description of On-Site Structures and Roads

No habitable structures are located on the subject site, as the boundaries lie within roadway and OCFCD ROW. Orangewood Avenue (a four-lane improved roadway), SR-57 ROW, and associated bridge structures are present on-sit e. Bridge structures include the Orangewood Avenue bridge over the Santa Ana River and the Orangewood Avenue Undercrossing structure associated with SR-57.

PACIFIC OCEAN
ORANGE
COUNTY

SAN DIEGO
COUNTY

RIVERSIDE
COUNTY

SAN BERNARDINO
COUNTY

LOS ANGELES
COUNTY
261
241
241
142
1 1
22 39
5 5
5 133
55 405
405
605
15 5
57 91
72 91
71 90
74 73
IMPERIAL HWY.

EDINGER AVE.

WARNER AVE.

IRVINE BLVD.

CROW
N VALLEY PKWY.

EASTERN TRANS. CORR.

WHITTIER BLVD.

BEACH BLVD.

EL TORO RD.

SANTIAGO CANYON RD.

CHAPMAN AVE.

IRVINE CENTER DR.

MOULTON PRKY.

STREET OF THE GO

LDEN LAN
T
ERN
JAMBOREE RD.

MACAR
THUR BLVD.

OLD NEWPORT BLVD.

YORBA LINDA BLVD.

SAN JOAQUIN HILLS
TRANS. CORRIDOR
PROP. FOOTHILL TRANS. CORRIDOR HARB
OR BLVD.

KATELLA AVE.

Newport
Beach
San
Clemente
Santa
Ana
Anaheim
Fullerton
La
Habra
Brea
Cypress
Buena
Park
Yorba
Linda
Villa Park
Anaheim
Hills
Mission
Viejo
Lake
Forest
Laguna
Beach
Dana
Point
San Juan
Capistrano
Laguna
Niguel
Orange
Huntington
Beach
Costa
Mesa
Seal
Beach
Garden
Grove Tustin
Irvine
Los
Alamitos
Subject Site
Subject Site
09/28/17 JN 159416 MAS
Exhibit 1
Regional Vicinity

ORANGEWOOD AVENUE IMPROVEMENTS
not to scale
0 2000'
Source: USGS Anaheim, CA and Orange, CA Quadrangles, dated 2015.

Subject SiteSubject Site
09/28/17 JN 159416 MAS
Exhibit 2
Site Vicinity

ORANGEWOOD AVENUE IMPROVEMENTS

FLOWER STFLOWER ST

DUPONT DRDUPONT DR

RAMPART STRAMPART ST

BITTERBUSH STBITTERBUSH ST STEVENS STSTEVENS STECKHOFF STECKHOFF ST

ECKHOFF STECKHOFF ST

POPLAR STPOPLAR ST

POPLAR STPOPLAR ST

SEQUOIA AVESEQUOIA AVE

SANTA ANA RIVER TRAILSANTA ANA RIVER TRAIL

CHERRY DRCHERRY DR

SPRUCE AVESPRUCE AVE

WILLOW AVEWILLOW AVE

SYCAMORE AVESYCAMORE AVE

ORANGEWOOD AVENUEORANGEWOOD AVENUE

BEVERLY DR

BEVERLY DR
Source: Aerial - Google Earth Pro, September 2017
Subject
Site
Subject
Site
09/28/17 JN 159416 MAS
Exhibit 3
Subject Site

ORANGEWOOD AVENUE IMPROVEMENTS
not to scale
57 57
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Orangewood Avenue Improvements Phase I ESA | 3-5

3.1.2 TOPOGRAPHY

The USGS maps show geological formations and their characteristics, describing the physical setting of an area through contour lines and major surface features including lakes, rivers, streams, buildings, landmarks, and other factors that impact the spread of contamination.

Additionally, the maps depict topography thro ugh color and contour lines and are helpful in determining elevations and site latitude and longitude.

Based on the USGS Anaheim, California Quadrangle, dated 2015, on-site topography is approximately 145 to 150 feet above mean sea level (msl), generally flat, and sloping down- gradient toward the Santa Ana River and then south. The subject site consists of roadway (Orangewood Avenue and SR-57) and OCFCD (Santa Ana River) ROW. The western portion of the subject site crosses the Santa Ana River, which generally flows in a south/southwest direction. A railroad is noted to the north and Park Royale is indicated to the southwest. No on- site structures, pits, ponds, or lagoons are noted on-site on this topographic map.

3.1.3 CURRENT USES OF ADJOINING PROPERTIES

For the scope of this Phase I ESA, properties are defined and categorized based upon their physical proximity to the subject site. An adjoin ing property is considered any real property or properties that border of which is contiguous or partially contiguous with that of the subject site, or that would be contiguous or partially contiguous with that of the subject site but for a street, road, or other public thoroughfare separating them. An adjacent property is any real property located off-site, which is not adjoining. The following is a detailed description of each adjoining land use observed on September 13, 2017:

 North: Commercial uses (Stadium Collection Business Center and Angel Stadium of Anaheim [Angel Stadium]) are located to the north of the subject site. Upstream areas of the Santa Ana River are also present to the no rth. SR-57 continues north of the subject site.
 East: Orangewood Avenue continues east of the subject site. Commercial uses are also present east of the subject site.
 South: Commercial uses (Orangewood Corpor ate Plaza and the Fire Training Center) are present to the south of the subject site. The Santa Ana River flows south of the subject site. SR-57 is also present to the south of the subject site.  West: Orangewood Avenue continues west of the subject site. Commercial uses (Angel Stadium, the Fire Trai ning Center, an office building [multiple tenants], and Karl Strauss Brewing Company) are located west of the subject site.

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Orangewood Avenue Improvements Phase I ESA | 3-6

3.1.4 GEOLOGIC CONDITIONS

3.1.4.1 Geology

The USGS Geological Map Index was searched by EDR for available Geological Maps that cover the subject site and surrounding areas. These Geological Maps indicate geological formations that are overlaid on a topographic map. Some maps focus on specific issues (i.e., bedrock, sedimentary rocks, etc.) while others may identify artificial fills (including landfills). Geological maps can be effective in estimating permeability and other factors that influence the spread of contamination.

According to the EDR GeoCheck Report, the land consists of a stratified sequence from the Cenozoic era. According to The Revised Platinum Triangle Expansion Project Subsequent Environmental Impact Report, dated August 2010, sedimentary formations underlying the area are comprised of consolidated and semiconsolidated sandstone, siltstone, and conglomerates of Cretaceous to late Tertiary age. Soils underlying the area are characterized by moderate to moderately rapid permeability, slow runoff, and a slight erosion potential.

3.1.4.2 Soils

The U.S. Department of Agriculture (USDA) Soil Conservation Service (SCS) Soil Survey Maps were searched for available soils within the subjec t site. Three (3) soil series are reported within the boundaries of the subject site; refer to Appendix C, Documentation, for a mapping of on-site soils. The following is a detailed description of each soil series located within the subject site:

 Hueneme Fine Sandy Loam, Drained (158): The landform for this soil is alluvial fans and the parent material is stratified alluvium derived from sedimentary rock. Hueneme fine sandy load is poorly drained. Slopes are 0 to 2 percent. There is no frequency of flooding or ponding associated with this soil.
 Metz Loamy Sand, Moderately Fine Substratum (164): The landform for this soil is alluvial fans and the parent material is mixed alluvium derived from igneous, metamorphic and sedimentary rock. Metz Loamy Sand, Moderately Fine Substratum is somewhat excessively drained. Runoff class is negligible. Slopes are 0 to 2 percent.

Frequency of flooding is rare and there is no frequency of ponding associated with this soil.
 Riverwash (191): The landform for this soil is fans and the parent material is sandy and gravelly alluvium. Slopes are 0 to 5 percent. Frequency of flooding is frequent.

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Orangewood Avenue Improvements Phase I ESA | 3-7

3.1.4.3 Radon

Radon is a radioactive gas that is found in cert ain geologic environments and is formed by the natural breakdown of radium, which is found in the earth’s crust. Radon is an invisible, odorless, inert gas that emits alpha particles, known to ca use lung cancer. Radon levels are highest in basements (areas in close proximity to the soil) that are poorly ventilated. A radon survey was not included within the scope of this investigation. According to the “U.S. EPA Map of Radon Zones,” the County of Orange is located within Zone 3, which has a predicted average indoor screening of less than 2.0 pCi/L (picocuries per liter). EPA recommends remedial actions when radon levels are greater than 4.0 pCi/L.

3.1.5 BIOLOGICAL SETTING

The subject site consists of paved asphalt, co ncrete, ornamental landscaping, and biological resources associated with the Santa Ana River.

3.1.6 DRAINAGE/HYDROLOGY

3.1.6.1 Drainage

Drainage of the subject site is accomplished by overland sheet flow, whic h enters the existing storm drainage system along Orangewood Avenue. The drainage in the subj ect site vicinity is anticipated to follow the general topography of the area, which is generally toward the Santa Ana River, than in a southern/southwestern direction towards the Pacific Ocean.

3.1.6.2 Flood Hazards

Flood Prone Area Maps published by the USGS show areas prone to 100-year floods overlaid on a topographical map. These maps are not considered the official Federal Emergency Management Agency (FEMA) flood maps; therefor e, in cases where a property is located immediately adjacent to or within the flood pr one boundary, a FEMA map should be obtained.

According to the EDR Database search and th e FEMA Flood Insurance Rate Maps (FIRM), the subject site (within the Santa Ana River) is loca ted within the 100-year flood zone (refer to the Appendix B, Database Records Searches, and Appendix C).

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Orangewood Avenue Improvements Phase I ESA | 3-8

3.1.6.3 Groundwater

Michael Baker assumes groundwater flow woul d follow the slope of the ground surface elevations towards the nearest open body of water or intermittent stream. The direction of this on-site flow is expected to generally be in a southern/southwestern direction.

3.2 STANDARD ENVIRONMENTAL

RECORDS SOURCES

The governmental sources have been searched by EDR (at the request of Michael Baker) for sites within the subject site and within an approximate one-mile radius of the subject site boundaries.

Upon completion of their search, EDR provided Michael Baker with their findings dated August 22, 2017. Michael Baker makes no claims as to the completeness or accuracy of the referenced sources. Our review of EDR's findings can only be as current as their listings and may not represent all known or potential hazardous waste or contaminated sites. To reduce the potential for omitting possible hazardous material sites on the subject site and within the surrounding area, sites may be listed in this report if there is any doubt as to the location because of discrepancies in map location, zip code, address, or other information. Refer to Appendix B for a listing and description of the Federal, tribal, State, and local records searched.

3.2.1 SUBJECT SITE

The lists that were reviewed did not report any regulatory properties within the boundaries of the subject site (refer to Exhibit 4, Overview Map). No known corrective action, restoration, or remediation has been planned, is currently taking place, or has been completed on the subject site. The subject site has not been under invest igation for violation of any environmental laws, regulations, or standards, as identified in the databases reported by EDR (refer to Appendix B).

3.2.2 OFF-SITE PROPERTIES

The lists that were reviewed reported multiple listed regulatory sites located within a one mile radius of the subject site that was listed in one or more of the regulatory databases identified in Appendix B. For a complete list of sites identifi ed and their status, refer to Appendix B. The following is a discussion of reported off-site properties.

60 kV
Source: EDR, Inc., 2017
09/11/17 JN 159416 MAS
Exhibit 4
Overview Map
ORANGEWOOD AVENUE IMPROVEMENTS • PHASE I ESA
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Orangewood Avenue Improvements Phase I ESA | 3-10
Adjoining Properties

The lists reviewed identified two properties ad joining the subject site (2211 West Orangewood Avenue and 2400 East Orangewood Avenue). The property located at 2211 West Orangewood Avenue was listed for having an underground storage tank. The property located at 2400 East Orangewood Avenue was listed for a historical underground storage tank (refer to Appendix B).

Refer to Table 3-1, Database Summaries, for a description of the regulatory databases reported in association with properties listed of concern. Refer to Table 3-2, Identified Regulatory Sites of Concern, for further evaluation of these properties listed of concern.

Table 3-1
Database Summaries

Database Description
AST The Aboveground Storage Tank database contains a listing of Petroleum Storage Tank Facilities Registered Aboveground Storage Tanks.

CA FID UST The CA FID UST database maintains information on properties where an underground storage tank is located.

CHMIRS The CHMIRS database maintains information on reported hazardous material incidents, i.e., accidental releases or spills. The source is the California Office of Emergency Services.

EMI The Emissions Inventory Data (EMI) database includes toxics and criteria pollutant emissions data that is collected by the Air Resources Board (ARB) and local air pollution agencies.

ENVIROSTOR
The Department of Toxic Substances Control’s (DTSC’s) Site Mitigation and Brownfields Reuse Program’s (SMBRP’s) EnviroStor database identifies sites that have known contamination or sites for which there may be reasons to investigate further. The database includes the following site types:

Federal Superfund sites (National Priorities List [NPL]); State Response, including Military Facilities and State Superfund; Voluntary Cleanup; and School sites. EnviroStor provides similar information to the information that was available in CalSites, and provides additional site information, including, but not limited to, identification of formerly-contaminated properties that have been released for reuse, properties where environmental deed restrictions have been recorded to prevent inappropriate land uses, and risk characterization information that is used to assess potential impacts to public health and the environment at contaminated sites.

HAZNET
The HAZNET database extracts data from the copies of hazardous waste manifests received each year by the DTSC. The annual volume of manifests is typically 700,000-1,000,000 annually, representing approximately 350,000-500,000 shipments. Data from non-California manifests & continuation sheets are not included at the present time. Data are from the manifests submitted without correction, and therefore many contain some invalid values for data elements such as generator ID, TSD ID, waste category, and disposal method. The source is the Department of Toxic Substance Control.

HIST CORTESE
The historic “Cortese” Hazardous Waste and Substances Sites List is a list of sites that are designated by the State Water Resources Control Board (SWRCB), the Integrated Waste Board, and the Department of Toxic Substances Control.

HIST UST The HIST UST database contains information on sites where historical underground storage tanks are located.

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Orangewood Avenue Improvements Phase I ESA | 3-11

Table 3-1 (continued)
Database Summaries

Database Description
NPDES National Pollutant Discharge Elimination System (NPDES) Permits Listing is a listing of NPDES permits, including stormwater.

RCRA-SQG
The Resource Conservation and Recovery Act (RCRA) – Small Qu antity Generator (SQG) database contains selective information on sites which generate, transport, store, treat, and/or dispose of hazardous waste as defined by RCRA. Small quantity generators generate less than 1,000 kilograms (kg) of hazardous waste, or over less than 1 kg of acutely hazardous waste per month. SQGs generate between 100 kg and 1,000 kg of hazardous waste per month.

SEMS-ARCHIVE
The Superfund Enterprise Management System Ar chive (SEMS-ARCHIVE) tracks sites that have no further interest under the Federal Superfund Program based on available information. The list was formerly known as the CERCLIS-NFRAP, renamed to SEMS ARCHIVE by the EPA in 2015. EPA may perform a minimal level of assessment work at a site while it is archived if site conditions change and/or new information becomes available. Archived sites have been removed and archived from the inventory of SEMS sites. Archived status indicates that, to the best of EPA’s knowledge, assessment at a site has been completed and that EPA has determined no further steps will be taken to list the site on the National Priorities List (NPL), unless information indicates this decision was not appropriate or other considerations require a recommendation for listing at a later time. The decision does not necessarily mean that there is no hazard associated with a given site; it only means that based upon available information, the location is not judged to be potential NPL site.

SLIC The SLIC (Spills, Leaks, Investigations, and Cleanup) program is designed to protect and restore water quality from spills, leaks, and similar discharges.

SWEEPS UST
The Statewide Environmental Evaluation and Planning System, the SWEEPS UST database also maintains information on properties where an underground storage tank is located, however, this database is no longer updated.

UST
The Underground Storage Tank (UST) database contains registered USTs. USTs are regulated under Subtitle I of the Resource Cons ervation and Recovery Act (RCRA). The data comes from the State Water Resources Control Board’s Hazardous Substance Storage Container Database.

WDS The Waste Discharge System (WDS) database is a listing of sites which have been issued waste discharge requirements.

Table 3-2
Identified Regulatory Sites of Concern

EDR
Map
ID#
Site
Name/Address
Direction from
Subject Site
Regulatory
Database EDR Site Status File Review1
1 Caremark Infant Care
2211 W.

Orangewood Avenue
Orange, CA 92868
Adjoining to the
north UST Site status was not reported in EDR.

YES
Michael Baker conducted a
file review at the OCHCA on
October 3, 2017.

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Orangewood Avenue Improvements Phase I ESA | 3-12
Table 3-2 (continued)
Identified Regulatory Sites of Concern

EDR
Map
ID#
Site
Name/Address
Direction from
Subject Site
Regulatory
Database EDR Site Status File Review1
A2
A3
A4
A5
Fire Station Training
Center
Anaheim Fire
Training Center
2400 East
Orangewood Avenue
Anaheim, CA 92805
Adjoining to the
southwest
Hist UST
AST

SWEEPS UST

CA FID UST
EMI
Hist UST reports one dies el fuel tank. SWEEPS
UST reports an active site status as of August 6,
1992
NO
Michael Baker requested files
from the OCHCA. However,
the OCHCA responded that
no files are available for
review.

B7
B8
C9
C10
YRC, Inc. (896)
Yellow Freight
System Inc.
700 N. Eckhoff Street
Orange, CA 92868
610 feet north of
subject site
UST

RCRA-SQG
SLIC
Hist UST

CA FID UST
CHMIRS
NPDES
WDS

SWEEPS UST
SLIC
RCRA-SQG reports the cla ssification as Small
Small Quantity Generator and historic generators
classification as Large Q uantity Generator. No
violations were found. SLIC REG 8 reported TCE
contamination to groundwater. The facility
received a closed status. Hist UST reports two
fuel tanks and one wastewater tank installed in
1972. CA FID UST reports an active site status.

CHMIRS reports notification of a 50-pound bag of
resin powder spill on August 1, 2012 and another
50-pound bag spill of toxic solid, Vanax DOTG,
on March 9, 2015. Cleanup was reported to be in
progress. Diatomaceous earth spill was reported
on March 2, 2015 and a half cup spill of
Azodicarbonamide was reported on July 22,
2016. A contractor was enroute to conduct a
cleanup of the release. On November 6, 2012, a
spill of Naxan Powder was reported. WDS
reports a minor threat to water quality. The facility
has an active status. SWEEPS UST reports two
fuel tanks and a waste oil tank with an action date
of February 19, 1992. Site status is active. SLIC
reports Toluene, Xylene, Diesel, and Gasoline
contaminated surface/structure, other
groundwater, and soil. Temporary
discontinuation of groundw ater monitoring and
agreement to maintain we lls (possible off-site
contamination) was reported on April 19, 1990.

Case closed/completed on November 10, 2009.

YES
Michael Baker reviewed
available online files
maintained by the RWQCB.

Based on a response from
the OCHCA, no OCHCA files
were available for review.

H31
H32
Inland Special Ties
Chemical Corp
Inland Specialties
Chemical Corporation
2023 W. Collins
Avenue
Orange, CA 92668

0.46-mile
northeast of
subject site
SEMS-

ARCHIVE

RCRA-SQG
HAZNET
HIST

CORTESE

ENVIROSTOR
SLIC
SEMS-ARCHIVE report ed discovery on
December 1, 1987; archive site and preliminary
assessment on November 10, 1988. RCRA-SQG
reported a Small Small Q uantity Generator. No
violations have been found. HAZNET reported

3.5 tons of halogenated solvents (chloroforms,
methyl chloride, perchloroethylene, etc.) in 2000.

2.125 tons of halogenated solvents were reported
and treated via incineration in 1999. 0.75 tons of
an unknown substance was reported and treated
via incineration in 1998. Two tons of halogenated
solvents were reported and treated via
incineration in 1998. 2 tons of other organic solids
were reported and treated via incineration in
YES
Michael Baker reviewed
available online files
maintained by the RWQCB
and conducted a file review at
the OCHCA on October 3,
2017.

Section 3.0 | Records Review

Orangewood Avenue Improvements Phase I ESA | 3-13
Table 3-2 (continued)
Identified Regulatory Sites of Concern

EDR
Map
ID#
Site
Name/Address
Direction from
Subject Site
Regulatory
Database EDR Site Status File Review1
1997. ENVIROSTOR reported halogenated
solvents release on July 1, 1982; site screening
was completed on June 1, 1995, May 2, 1995,
September 19, 1988, April 15, 1988, and May 4,
1987; and a preliminary assessment report was
completed on May 4, 1988. SLIC reported
potential contaminants of concern:

Trichloroethane, Tetr achloroethylene, and
Trichloroethylene. A vapor extraction system was
installed in 1996. Monitoring wells were installed
and have been non-detect since 1997. Case
closed/completed on April 7, 2005.

Notes: RWQCB: Los Angeles Regional Water Quality Control Board; OCHCA = Orange County Health Care Agency

1. Refer to Section 3.3, File Record Reviews, for a discussion of files reviewed, if applicable.

Source: Environmental Data Resources, Inc., EDR Radius Map with GeoCheck, dated August 22, 2017; refer to Appendix B, Database Records Searches.

Adjacent Properties

24 adjacent properties were listed surrounding th e subject site. However, only two adjacent regulatory properties have been identified th at present a potential concern to groundwater underlying the subject site. Refer to Table 3- 1 and Table 3-2 above, for a description of the regulatory databases reported in association with properties listed. Refer to Table 3-3, for further evaluation of these adjoining properties listed.

All other reported adjacent regulatory properti es are considered to have a low potential of affecting the subject site for one or more of the following reasons: distance from the subject site, direction of anticipated groundwater flow, site status, and/or no contamination has been reported. Refer to Appendix B for a listing of all adjacent properties reported.

3.2.3 UNMAPPED PROPERTIES

According to EDR’s ESA Report Desktop Refere nce, dated 1996, some reported sites are unmappable as exact locations remain undefined. Listings in publically available records, which do not have adequate address information, are ge nerally not considered practically reviewable.

For the purposes of this Phase I ESA, practically reviewable information is defined as information provided in a manner and in a form that yields information without the need for extraordinary analysis or irrelevant data. Although the locati on of these sites may be unknown, the site and detail information are often available through the EDR.

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Orangewood Avenue Improvements Phase I ESA | 3-14

Michael Baker’s review of Unmapped Properties consisted of a verification, based solely on the professional judgment of the Environmental Professi onal, that the subject site is not listed (i.e., referenced by name or street address) and review to identify if any of the Unmapped Properties cause a likely potential to create an REC within the boundaries of the subject site. No listed Unmapped Properties appear to be located within the boundaries of the subject site. Also, potentially contaminated groundwater underlying the subject site as a result of the reported Unmapped Properties is considered unlikely, due to the anticipated distance from the subject site, gradient, and/or the status of the identified site.

3.3 FILE RECORD REVIEWS

If the subject site or any of the adjoining properties are identified on one or more of the standard environmental record sources, pertinent regulatory files and/or records associated with the listing should be reviewed. The purpose of the regulatory file review is to obtain sufficient information to assist the environmental professional in determining if a REC, HREC, CREC, or a de minimis condition exists at the property in connection with the listing. If, in the environmental professional’s opinion, such a review is not warranted, the environmental professional must explain the justification for not conducting the regulatory file review.

Michael Baker requested available files for revi ew at the Orange County Health Care Agency (OCHCA) on August 29, 2017 for those properties of concern identified in Table 3-2. The OCHCA had available records for two of the properties. The following is a summary of Michael Baker’s review of the OCHCA’s files reviewed on October 3, 2017:

 2211 West Orangewood Avenue: Based on the file review, the property is located at 2211 East Orangewood Avenue and EDR miss-mapped this property. As this site is not adjoining the subject site, but is actually situated greater than 1,400 feet west of the subject site, this property is no longer of concern.

 2023 West Collins Avenue: Records reviewed applied to a current use, the OC Public Works Fleet Service Shop 2, which is a hazardous waste generator. No indication of a release was noted in association with the facility. No other records pertaining to other past uses or actual releases was noted.

In addition to those files available by the OCHCA, Michael Baker searched the online GeoTracker database maintained by the State Water Resources Control Board (SWRCB) for file information relative to the adjoining properties of concer n in September 2017. GeoTracker was developed pursuant to a mandate by the California State Legislature to investigate the feasibility of Section 3.0 | Records Review

Orangewood Avenue Improvements Phase I ESA | 3-15
establishing a statewide Geographic Information System (GIS) for leaking underground storage tanks (LUST) sites and is maintained by the SWRCB. Michael Baker makes no claims as to the completeness or accuracy of GeoTracker; our review of GeoTracker’s findings can only be as current as their listings and may not represen t all known or potential hazardous waste or contaminated sites. Available online files were reviewed for the following off-site properties:

700 North Eckhoff Street: This property reported a release to soil and was closed by the RWQCB on November 10, 2009. However, the case clos ure letter identified groundwater contamination at this property (which is only 588 feet up-gradient of the subject site) as a result of the off-site property 2023 West Collins Street (which is situated approximately 2,420 feet up gradient from the subject site).

2023 West Collins Street: This off-site property (situated approximately 2,420 feet up gradient from the subject site) reported a release of 1, 1,1-Trichloroethane (TCA), Tetrachloroethylene (PCE), Trichloroethylene (TCE) to soil and ground water. A vapor extraction system (VES) was installed in 1996 and since 1996, approximately 2,000 pounds of VOCs have been removed through this process. As VES was no longer ef fective in removing residual VOCs from the soil and the site being consistent with the RWQCB’s low threat policy, this ca se was closed on April 7, 2005.

Based on the files reviewed as part of 700 North Eckhoff Street, groundwater down-gradient this property as far as 6,500 feet re main impacted by this release (although case closure has been achieved). As the subject site is located with in this impact area, this reported groundwater contamination is of concern.

3.4 HISTORICAL USE INFORMATION ON THE

SUBJECT SITE AND ADJOINING PROPERTIES

The objective of consulting historical sources is to develop a history of the previous uses of the property and surrounding area, in order to help identify the likelihood of past uses having led to RECs in connection with the property. The Environmental Professional shall exercise professional judgment and consider the possible releases that might have occurred at a property in light of the historical uses and, in concert with other relevant information gathered as part of the Phase I ESA process, use this information to assist in identifying RECs (discussed in Section

6.0, Evaluation, of this Phase I ESA).

The standard sources identified by ASTM E 1527-13 include aerial photographs, fire insurance maps, property tax files, recorded land title records (a chain-of-title), historical USGS topographic maps, local street directories, building depart ment records, zoning/land use records, prior Section 3.0 | Records Review

Orangewood Avenue Improvements Phase I ESA | 3-16
assessments, and other historical sources (i.e., any source or sources, other than those listed, that are credible to a reasonable person and that identi fy past uses of the property). The focus is on usage rather than ownership, which is why a chain-of-title is not sufficient by itself.

3.4.1 METHODOLOGY AND LIMITING CONDITIONS

3.4.1.1 Methodology

Data failure (a subset of a data gap) occurs wh en all of the standard historical sources that are reasonably ascertainable and likely to be useful have been reviewed and yet the historical source review objectives have not been met.

USES OF THE PROPERTY

Per ASTM E 1527-13 Standard Practice, historical uses “shall be identified from the present, back to the property’s obvious first development use including (agricultural and fill activities), or back to 1940, whichever is earlier.” This task requires reviewing only as many of the standard historical sources as are necessary and both reasonably ascertainable and likely to be useful.

Historical information for the subject site was obtained back to 1896, at which time the subject site was vacant land. Sources reviewed have been cited throughout this section and are referenced in Section 7.0, References, of this Phase I ESA.

INTERVALS

Review of standard historical sources at less than approximately five year intervals is not required by ASTM E 1527-13 Standard Practice. If the specific use of the property appears unchanged over a period longer than five years, then it is no t required by ASTM E 1527-13 Standard Practice to research the use during that period. Michael Baker did not encounter data failure with regard to source intervals during the course of this Phase I ESA.

USES OF PROPERTIES IN SURROUNDING AREA

Uses in the area surrounding the property shall be identified in the Phase I ESA, but this task is only required to the extent that this informatio n is revealed in the course of researching the property itself. If the environmental professional uses sources that include the surrounding area, surrounding uses should be identified to a distance determined at the discretion of the environmental professional. Factors to consider in making this determination include, but are not limited to:

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Orangewood Avenue Improvements Phase I ESA | 3-17
 The extent to which information is reasonably ascertainable;  The time and cost involved in reviewing surrounding uses;  The extent to which information is useful, a ccurate, and complete in light of the purpose of the records review;
 The likelihood of the information being sign ificant to RECs in connection with the property;
 The extent to which potential concerns are obvious;
 Known hydrogeologic/geologic conditions t hat may indicate a high probability of hazardous substances or petroleum products migration to the property;  How recently local development has taken place;
 Information obtained from interviews and other sources; and  Local good commercial and customary practice.

Surrounding land uses have been noted througho ut the Phase I ESA, as applicable, and are referenced accordingly.

3.4.1.2 Limiting Conditions

Michael Baker did not encounter any limiting condit ions that limited the historical use review during the course of this Phase I ESA.

3.4.2 STANDARD HISTORICAL SOURCES

3.4.2.1 Historical Uses Summary

Based upon the evaluation of documented land use as demonstrated in the resources reviewed as part of this Phase I ESA, the subject site appears to have consisted of a portion of the Santa Ana River and vacant land by 1896. The vacant portio n of the subject site consisted of agricultural uses by 1938. Orangewood Avenue was constructed by 1966 and reconfigured by 1972. SR-57 and the Orangewood Avenue/SR-57 interchange wa s constructed by 1977. The subject site has remained a transportation land use to the pres ent. The surrounding area appears to have historically consisted of agriculture uses un til the 1960’s, at which time residential and commercial uses began and continued through the 1980’s. Construction of the Anaheim Stadium occurred in the 1960’s and construction of SR-57 in the 1970’s. By the 1980’s, the surrounding uses appear to have been fully developed and has generally remained unchanged to the present day. Refer to Table 3-3, Historical Uses Summary.

Section 3.0 | Records Review

Orangewood Avenue Improvements Phase I ESA | 3-18
Table 3-3
Historical Uses Summary

Year On-Site Use Surrounding Uses Source
1896
The western portion of the subject site
appears to consist of the Santa Ana
River and the eastern portion appears
to consist of vacant land.

The Santa Ana River traverses the western
portion of the subject site in a northeast to
southwest direction. Four railroad lines
surround the subject site: Union Pacific
Railroad appears to travel in a west/east
direction, north of the subject site and in a
northwest/southeast direction, southwest of
the subject site; and Burlington Northern
Santa Fe Railroad appears to travel in a
northwest to southeast direction, north of the
subject site and in a north/south direction,
east of the subject site. Sparse structures
and infrastructure is noted in the area. The
developing area of Orange is present to the
southeast.

USGS Topographic Maps
1898 No changes noted. No changes noted. USGS Topographic Maps 1901 No changes noted.

Transportation uses and development
surrounding the subject site increased.

Tustin Junction is noted northwest of the
subject site.

USGS Topographic Maps
1902 No changes noted. No changes noted. USGS Topographic Maps 1932 Unmapped. Transportation uses and development
surrounding the subject site increased. USGS Topographic Maps 1935 No changes noted.

West Anaheim Junction is noted west of the
subject site. Santa Ana Boulevard (also
noted as US Highway 101) runs parallel to
the Union Pacific Railroad, southwest of the
subject site. Mausoleum is noted west of the
subject site. County Farm and Hospital is
noted southwest of the subject site.

Placentia, running in north/south direction, is
noted as a highway west of the subject site.

USGS Topographic Maps
1938 The eastern portion of the subject site
appears to consist of agricultural uses.

The land adjoining the subject site to the
north/northeast, east, and south/southeast
appears to consist of agricultural uses.

Aerial Photographs
1942
A levee is noted on both the west and
east bank of the Santa Ana river within
the boundaries of the subject site.

A levee is noted on both the west and east
bank of the Santa Ana river, north and south
of the subject site. SR-22 is noted traveling
in a west/east direction, south/southwest of
the subject site. Transportation uses and
development surrounding the subject site
increased. A developed area is noted
southeast of the subject site.

USGS Topographic Maps
1947 No changes noted.

The land adjoining the subject site to the
west, northwest, and southwest appears to
be used for agricultural purposes.

Aerial Photographs
1949 No changes noted.

US Highway 101 is noted as a four-lane
freeway. Additional street names are noted
including Parker Avenue.

USGS Topographic Maps
Section 3.0 | Records Review

Orangewood Avenue Improvements Phase I ESA | 3-19
Table 3-3 (continued)
Historical Uses Summary

Year On-Site Use Surrounding Uses Source
1950 No changes noted. No changes noted. USGS Topographic Maps 1952 No changes noted. No changes noted. Aerial Photographs 1963 No changes noted. Increased residential development has occurred to the south of the subject site. Aerial Photographs 1964, 1965 No changes noted.

Anaheim Stadium is noted northwest of the
subject site. A Drive-in Theater is noted
southwest of the subject site. Sycamore
School and Portola Junior High School are
noted southeast of the subject site. US
Highway 101 is noted as I-5. Freeway
interchanges are noted along SR-22 and I-5.

USGS Topographic Maps
1966
Orangewood Avenue bridge over the
Santa Ana River is being constructed.

A temporary road has been
constructed during bridge
construction.

No changes noted. Aerial Photographs
1972
The temporary road has been
removed and the Orangewood
Avenue bridge and roadway traverses
the subject site in a west/east
direction. No other roadways travers
the site.

Additional land disturbance, development,
and transportation uses are noted
surrounding the subject site.

Aerial Photographs,
USGS Topographic Maps
1977
State Route 57 is built and the freeway
traverses the subject site in a general
north/south direction midway through
the site. The Orangewood/SR-57
interchange is noted within the middle
and eastern portions of the subject
site.

Additional development is noted east and
northeast of the subject site. Aerial Photographs
1981 No changes noted. No changes noted. USGS Topographic Maps 1985 No changes noted.

Adjoining properties to the southwest,
northeast, and southeast are developed with
structures. The land surrounding the subject
site appears to be fully developed.

Aerial Photographs
1989 No changes noted. Redevelopment of a property is noted northeast of the subject site. Aerial Photographs
1990 No changes noted. No changes noted. Aerial Photographs 1995 No changes noted.

The Santa Ana River appears to be
disturbed. A new structure is noted at a
property located northeast of the subject
site.

Aerial Photographs
2005 No changes noted.

The Santa Ana River appears to have a
hydraulic or water quality system in place.

Structures located southwest of the subject
site has been demolished and the property
graded.

Aerial Photographs
Section 3.0 | Records Review

Orangewood Avenue Improvements Phase I ESA | 3-20
Table 3-3 (continued)
Historical Uses Summary

Year On-Site Use Surrounding Uses Source
2009 No changes noted. Redevelopment is noted southwest of the subject site Aerial Photographs
2010 No changes noted. No changes noted. Aerial Photographs 2012 No changes noted. Additional development and transportation uses are noted.

Aerial Photographs,
USGS Topographic Maps
Notes:

Bold denotes an interval data gap, as described in Section 3.4.1.1, Methodology, Intervals.

Other sources reviewed, but that which did not include information pertaining to the subject site included the following: Sanborn Maps and City Directory.

Source: Refer to Section 7, References, and Appendix C, for full citation and documentation of sources utilized in this table.

3.4.2.2 Property Tax Files

Michael Baker searched the subject site for property data via First American Real Estate Solutions and the legal description for the subject site. This data typically provides current property ownership information and includes information regarding on-site improvements, zoning, land use, transfer of last sale, and other miscellaneou s structural improvements. Because the subject site lies within roadway/floodway ROW and there are no on-site APNs or addresses, property information for this site was not available for review.

3.4.2.3 Zoning/Land Use Records

Zoning/land use records generally consist of records maintained by the local government in which the subject site is located. They indicate the uses permitted by the local government for particular zones within its jurisdiction. The records may consist of maps and/or written records. Because the subject site lies within roadway/floodway ROW, there are no zoning/land use records that apply.

3.4.2.4 Oil and Gas Wells

Michael Baker reviewed the California Departme nt of Oil, Gas, and Geothermal Resources (DOGGR) online mapping system on August 30, 2017, which indicates existing and historical oil and gas wells within the immediate vicinity of the subject site. Current well status for any well indicated in the online mapping system should be confirmed at the appropriate Division of Oil and Gas District Office. According to DOGGR, no oil or gas wells are located within the subject site and the subject site does not appear to be situated in an oil or gas field (refer to Appendix C).

Section 3.0 | Records Review

Orangewood Avenue Improvements Phase I ESA | 3-21

3.4.2.5 Other Historical Sources

Michael Baker reviewed the hazardous materials analysis associated with the Draft Environmental Impact Report for The revised Platinum Triangle Expansion Project Subsequent Environmental Impact Report No. 339 (Platinum Triangle SEIR No. 339), dated August 2010. Based on Platinum Triangle SEIR No. 339, database re cords searches were conducted as part of the Anaheim Stadium Area Master Land Use Plan FEIR No. 321 in 1999 and the FSEIR No. 332 in 2005 to identify properties that could potentially pose a variety of environmental hazards within the boundaries and immediately adjacent to The Pl atinum Triangle. Action status on many of the identified properties were “closed” and re quired no further remediation and some were undergoing environmental remediation. Ho wever, the Platinum Triangle SEIR No. 339 concluded that these impacts are site-specific and implementation of Mitigation Measures 5.4-1 through 5.4-7 of MMP No. 106A, prepared for FS EIR No. 332, would ensure that identified hazardous waste and/or hazardous material would be handled and disposed of in the manner specified by the State California Hazardous Subs tances Control Law (Health and Safety Code, Division 20, Chapter 6.5) and according to the requirements of the California Administrative Code, Title 30, Chapter 22.

Orangewood Avenue Improvements Phase I ESA | 4-1

SECTION 4.0

SITE RECONNAISSANCE

According to the ASTM E 1527-13 Standard Practice, the objective of the site reconnaissance is to obtain information indicating th e likelihood of identifying RECs in connection with the subject site.

4.1 METHODOLOGY AND LIMITING CONDITIONS

4.1.1 METHODOLOGY

Michael Baker performed a visual observation of readily accessible areas of the subject site and immediately adjoining properties on September 13, 2017. At this time, the subject site was visually inspected. Refer to Exhibit 5, On-Site Photographs, and Exhibit 6, Off-Site Photographs, for photograph documentation conducted during the site visit. The subject site was viewed from all public thoroughfares. If roads or paths with no apparent outlet are observed on the subject site, the use of the road or path was identified to determine whether it was likely to have been used as an avenue for disposal of hazardous substances or petroleum products.

4.1.2 LIMITING CONDITIONS

No limiting conditions were encountered as part of Michael Baker’s site visit conducted on September 13, 2017.

4.2 ON-SITE OBSERVATIONS

4.2.1 DESCRIPTION OF ON-SITE USES

The subject site consists of transportation uses.

4.2.2 DESCRIPTION OF ON-SI TE STRUCTURES AND ROADS

The subject site consists of Orangewood Aven ue and OCFCD ROW (Santa Ana River). Other than two bridge structures, no on-site habitable structures are present.

View of the eastern portion of the subject site looking west.

View looking west at the existing on-site Orangewood Avenue bridge structure over the Santa Ana River.

View of the eastern portion of the subject site looking east.

View looking west at existing Orangewood Avenue Undercrossing bridge structure. 09/19/17 JN 159416 MAS
Exhibit 5
On-Site Photographs
ORANGEWOOD AVENUE IMPROVEMENTS • PHASE I ESA
View of commercial land use (Orangewood Corporate Plaza) south of the eastern portion of the subject site.

View of the Santa Ana River and Angel Stadium located to the north and northwest, respectively, of the subject site.

View of commercial land use (Stadium Collection Business Park) north of the eastern portion of the subject site.

View of the existing Fire Training Center located to the southwest of the western portion of the subject site.
09/19/17 JN 159416 MAS
Exhibit 6
Off-Site Photographs
ORANGEWOOD AVENUE IMPROVEMENTS • PHASE I ESA
Section 4.0 | Site Reconnaissance

Orangewood Avenue Improvements Phase I ESA | 4-4

4.2.3 DESCRIPTION OF PAST USES OF THE SUBJECT SITE

Based on review of available documentation noted in Section 3.0, Records Review, past uses of the subject site appear to have consisted of a portion of the Santa Ana River and vacant land by 1896.

The vacant land became agricultural land uses by 1938. Orangewood Avenue was constructed by 1966 and reconfigured by 1972. SR-57 and the Orangewood Avenue/SR-57 interchange was constructed by 1977. The subject site has remained a transportation land use to the present. No evidence to suggest the presence of other past uses was noted during the site visit.

4.2.4 HAZARDOUS SUBSTANCES AND PETROLEUM PRODUCTS

Michael Baker did not observe hazard ous substances or petroleum pr oducts at the subject site.

No staining or evidence of leaking was observed.

4.2.5 CHEMICAL STORAGE TANKS (ASTS AND USTS)

During the September 13, 2017 site inspection the subject site wa s inspected for fill pipes, vent pipes, areas of abnormal or heavy staining, manways, manholes, access covers, concrete pads not homogenous with surrounding surfaces, concrete build-up areas potentially indicating pump islands, abandoned pumping equipment, or fuel pumps. Michael Baker did not observe any evidence of aboveground storage tanks (ASTs) or underground storage tanks (USTs) on the subject site during the September 13, 2017 site visit.

4.2.6 SPILLS

Michael Baker did not observe evidence of spills during the September 13, 2017 site visit.

4.2.7 SOLID WASTE DISPOSAL

No indication of on-site solid waste disposal pr actices (i.e., landfills) was apparent during the September 13, 2017 site inspection.

4.2.8 UTILITIES

Typical roadside utilities were noted during the September 13, 2017 site inspection. Evidence of underground utilities (i.e., tele phone cable, sewer, and othe r water-related utilities) and aboveground electrical utilities (i.e., streetlights, electrical boxes, and overhead power lines) were Section 4.0 | Site Reconnaissance

Orangewood Avenue Improvements Phase I ESA | 4-5
noted throughout the vicinity of the subject site. No staining or leakage was noted with respect to on-site utilities.

4.2.8.1 Polychlorinated Biphenyls (PCBs)

No power poles were observed on-site during the September 13, 2017 site visit.

4.2.8.2 Wells

No water wells were observed within the boundaries of the subject site during the September 13, 2017 site visit.

4.2.8.3 Potable Water Supply

The subject site vicinity appeared to be connect ed to a water line, which was noted via manhole covers along on-site roadways. No evidence to suggest the presence of on-site water wells was noted.

4.2.8.4 Sewage Disposal System

The subject site vicinity appeared to be connected to existing sewer utilities. No evidence of other sewage disposal systems (including septic systems) was noted during the site visit.

4.2.8.5 Heating/Cooling

No habitable structures are located on-site; Mi chael Baker did not observe heating or cooling systems during the site visit.

4.2.9 DRAINS AND SUMPS

Storm drain systems (curb and gutter) were noted along the roadways in the vicinity of the subject site during the September 13, 2017 site visit.

4.2.10 PITS, PONDS, LAGOONS

No pits, ponds, or lagoons were noted during the September 13, 2017 site visit.

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Orangewood Avenue Improvements Phase I ESA | 4-6

4.3 OFF-SITE OBSERVATIONS

An adjoining property is considered any real property or properties that the border of which is contiguous or partially contiguous with that of the subject site, or that would be contiguous or partially contiguous with that of the subject site but for a street, road, or other public thoroughfare separating them. An adjacent property is any real property located off-site, which is not adjoining. Visual observations of the publicly accessible portions of adjoining properties were conducted on September 13, 2017 as part of this Phase I ESA and are described below.

4.3.1 DESCRIPTION OF CURRENT AND

PAST USES OF THE SURROUNDING AREA

Current uses surrounding the subject site prim arily consist of transportation, commercial, residential, and water-related land uses. Based on review of available documentation noted in Section 3.0, past uses of the surrounding area appear to have consisted of agriculture uses until the 1960’s. Development increased between the 1960’s and 1970’s, including construction of the Anaheim Stadium in the 1960’s and construction of SR-57 in the 1970’s, while agriculture decreased. By the 1980’s, the surrounding uses appear to be fully developed and has generally remained unchanged to the present day.

4.3.2 DESCRIPTION OF CURRENT USES AND

STRUCTURES AT ADJOINING PROPERTIES

The following is a detailed description of each adjoining land use observed on September 13, 2017:

 North: Commercial uses (Stadium Collection Business Center) are located to the north of the subject site. Upstream areas of the Sa nta Ana River are also present to the north.

SR-57 continues north of the subject site.
 East: Orangewood Avenue continues east of the subject site. Commercial uses are also present east of the subject site.
 South: Commercial uses (Orangewood Corporat e Plaza) is present to the south of the subject site. The Santa Ana River flows south of the subject site. SR-57 is also present to the south of the subject site.
 West: Orangewood Avenue continues west of the subject site. Commercial uses (Angel Stadium of Anaheim [Angel Stadium] and the Fire Training Center) are located west of the subject site.

Section 4.0 | Site Reconnaissance

Orangewood Avenue Improvements Phase I ESA | 4-7

4.3.3 DESCRIPTION OF PAST USES AND

STRUCTURES AT ADJOINING PROPERTIES

Based on the available documentation noted in Section 3.0, adjoining land uses appear to have historically consisted of agricultural land uses. No evidence of past uses was observed during the site visit.

4.3.4 OBSERVATIONS OF OFF-SITE PROPERTIES

4.3.4.1 Utilities

Typical roadside utilities (e.g., stormwater drainag e, sewer, irrigation, and electrical utilities including overhead power lines and pole-mounted electrical transformer s) were noted during the site inspection. No staining or leakage was observed with respect to off-site utilities.

4.3.4.2 Chemical Storage Tanks

No evidence of chemical storage tanks was observ ed at off-site properties during the September 13, 2017 site visit.

4.3.4.3 Hazardous Materials

During a preliminary observation of adjoining properties from public thor oughfares, no visible or physical evidence was observed to suggest that hazardous substances and/or petroleum- based material are handled/stored/u sed or have been recently released into the environment.

No unusual or suspicious materials handling or storage practices were observed with respect to adjacent properties.

Orangewood Avenue Improvements Phase I ESA | 5-1
SECTION 5.0

INTERVIEWS

The ASTM E 1527-13 Standard Practice indicates th at the objective of interviews is to obtain information indicating RECs in connection with the subject site. Interviews with past and present owners, operators, and occupants of the property consist of questions to be asked in the manner and of persons as described in the ASTM E 1527- 13 Standard Practice. The content of questions to be asked shall attempt to obtain information about uses and conditions observed during the site reconnaissance as well as the documentation review. The content of questions to be asked of State and/or local government o fficials shall be decided in the discretion of the environmental professional(s) conducting the Phase I ESA, pr ovided that the questions shall generally be directed towards identifying RECs in connection with the subject site.

5.1 PROPERTY OWNER

Due to the nature of the project (roadway improvements), current and past property owners were not readily available for interview.

5.2 KEY SITE MANAGER/OPERATOR

A key site manager is a person with good knowle dge of the uses and physical characteristics of the property. Often the Key Site Manager is the property manager, the chief physical plant supervisor, or head maintenance person. If the us er is the current property owner, the user has an obligation to identify a key site manager, even if it is the user himself or herself.

Mr. Brendan Dugan, P.E., with Michael Baker Inte rnational, has been identified as the Key Site Manager for the purposes of this analysis. Mr. Dugan has provided Michael Baker with information pertaining to the subject site throughout this Phase I ESA, which has been referenced accordingly.

5.3 OCCUPANTS

No occupants are associated with the subject site, as the site consists of transportation uses and OCFCD ROW. Thus, no occupants are available fo r interview during the course of this Phase I ESA.

Section 5.0 | Site Reconnaissance

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5.4 LOCAL GOVERNMENT OFFICIALS

Michael Baker did not interview local government officials at the time of this Phase I ESA.

5.5 OTHER PERSONS

No other persons were interviewed during the course of this Phase I ESA.

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SECTION 6.0

EVALUATION

Michael Baker has performed a Phase I ESA in ge neral conformance with the scope of services and limitations of ASTM E 1527-13 Standard Practice for the Orangewood Avenue Improvements Project, located in the cities of Anaheim and Orange, Orange County, State of California. Any exceptions to, or deletions from, this practice are described in Section 6.3, Limiting Conditions/Deviations, of this report. This Phase I ESA has revealed the following in connection with the subject site.

6.1 FINDINGS AND OPINIONS

The following findings and opinions are based upon review of reasonable ascertainable referenced material available to Michael Baker during the preparation of this Phase I ESA, which included a review of historical aerial photographs, historical topographic maps, regulatory databases, and other documentation, as well as interviews and site reconnaissance.

6.1.1 CURRENT ON-SITE USES

The subject site currently consists of transport ation uses (Orangewood Avenue and SR-57) and OCFCD ROW. Although no buildings are loca ted on-site, two bridge structures (the Orangewood Avenue Undercrossing and the Orang ewood Avenue bridge over the Santa Ana River) are located within the subject site.

6.1.1.1 Bridge Structures

Asbestos-Containing Materials

Asbestos is a strong, incombustible, and corrosion resistant material, which was used in many commercial products since prior to the 1940s and up until the early 1970s. If inhaled, asbestos fibers can result in serious health problems. Asbestos containing-materials (ACMs) are building materials containing more than one percent (1%) asbestos (some state and regional regulators impose a one-tenth of one percent (0.1%) threshold). As ACMs are commonly known to be used in building materials for bridge structures, AC Ms may be present in the two on-site bridge structures (Orangewood Avenue bridge co nstructed in 1966 and Orangewood Avenue Undercrossing constructed in 1977 or earlier). The on-site bridge structures appeared to be in fair condition and no visible evidence to suggest the release of ACMs into the environment was Section 6.0 | Evaluation

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observed. Therefore, it is Michael Baker’s opin ion that the on-site bri dge structures have not resulted in a REC on the subject site as a result of ACMs.

Lead-Based Paints

Until 1978, when the U.S Consumer Product Safety Commission (CPSC) phased out the sale and distribution of residential paint containing lead, many homes were treated with paint containing some amount of lead. It is estimated that over 80 percent of all housing built prior to 1978 contains some LBP. The mere presence of lead in paint may not constitute a material to be considered hazardous. In fact, if in good condition (no flaking or pealing), most intact LBP is not considered to be a hazardous material. In poor condition LBPs can create a potential health hazard for building occupants, especially children. As LBPs are commonly known to be used in building materials for bridge structures, LBPs may be present in association with guard railings on the on- site bridge structures. The on-site bridge structures appeared to be in fair condition and no visible evidence to suggest the release of LBPs into the environment was observed. Therefore, it is Michael Baker’s opinion that the on-site bridge structures have not resulted in a REC on the subject site as a result of LBPs.

6.1.1.2 Traffic Striping Material

LBPs were commonly used in traffic striping ma terials before the discontinued use of lead chromate pigment in traffic striping/marking materials and hot-melt Thermoplastic stripe materials (discontinued in 1996 and 2004, respective ly). Michael Baker observed traffic striping along Orangewood Avenue during the September 13, 2017 site visit. Thus, LBPs may be present within traffic striping. Traffic striping was noted to be in good condition.

On-site traffic striping is currently contained, with no visible evidence to suggest the release of LBPs into the environment. Therefore, it is Michael Baker’s opinion that the likely presence of LBPs in the traffic striping materials has not resulted in a REC at the time of this Phase I ESA.

6.1.1.3 Orange County Flood Control District ROW

The proposed project would require partial acquis ition of land within the OCFCD ROW. These areas of acquisition are not associated with priv ate property and no addresses apply. The Santa Ana River is lined with cement and, as a result, no residual soil contamination from surface flows is anticipated. Further, the subject site has not been reported in any regulatory databases reported by EDR. No evidence of hazardous materials was observed during the September 13, 2017 site visit. Based on the information reviewed as part of this Phase I ESA, it is the opinion of Michael Baker that these areas of acquisition have not resulted in a REC at the time of this Phase I ESA.

Section 6.0 | Evaluation

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6.1.2 PAST ON-SITE USES

Based upon the evaluation of documented land use as demonstrated in the resources reviewed as part of this Phase I ESA, the subject site appears to have consisted of vacant land, water-related uses (Santa Ana River), and agricultural uses prior to the 1960’s. No past on-site structures were documented in the resources reviewed. Ava ilable public records provided by EDR were reviewed by Michael Baker on August 23, 2017. The lists that were reviewed did not report any regulatory properties within the boundaries of the subject site. Therefore, no known corrective action, restoration, or remediation has been pl anned, is currently taking place, or has been completed on the subject site. The subject site has not been under investigation for violation on any environmental laws, regulations, or standards, as identified in the databases reported by EDR. The following are Michael Baker’s findings regarding past on-site uses.

6.1.2.1 Aerially Deposited Lead

Aerially Deposited Lead (ADL) refers to lead de posited on highway shoulders from past leaded fuel vehicle emissions. Accord ing to the Caltrans ADL webpage, 1 although lead was banned as
a fuel additive in California be ginning in 1992, ADL may still be present in soils adjacent to highways in use prior to that time.

Based on historical aerial photographs and US GS topographic maps, SR-57 was constructed in 1977. Thus, it is anticipated that SR-57, in the vicinity of the subject site, has been utilized by a high volume of traffic since then. The potentia l for lead contamination to exist within exposed soils on-site due to aerially deposited lead is likel y. It is Michael Baker’s opinion that there is a REC on the subject site as a result of ADL.

6.1.2.2 Agricultural Uses

Based upon evaluation of the documented land us e as demonstrated in the reviewed resources, the series of historical aerial photographs and maps, and the site inspection, the subject site appears to have been historically utilized for agricultural purposes (row crops within the eastern portion of the subject site from approximatel y the 1930’s through the 1960’s). Therefore, a combination of several commonly used pesticid es (i.e., Dichlorodiphenyldichloroethane [DDD], Dichlorodiphenyltrichloroethane [DDT], Dichlorodiphenyldichloroethylene [DDE]), which are now banned, may have been used throughout the su bject site. The historical use of agricultural pesticides may have resulted in pesticide residues of certain persis tence in soil at concentrations

1 Soil Management Agreement for Aerially Deposited Lead-Contaminated Soils (effective July 1, 2016). Aerially Deposited Lead .

California Department of Transportation. Accessible online at (http://www.dot.ca.gov/hq/env/haz/hw_adl.htm). Accessed September 28, 2017.

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that are considered to be hazardous based on established federal regulatory levels. The primary concern with historical pesticide residues is human health risk from inadvertent ingestion of contaminated soil, particularly by children. The presence of moderately elevated pesticide residuals in soil presents potential health and marketplace concerns.

Although the subject site historically included agricultural uses, since then SR-57 and other transportation uses, as well as commercial uses in the surrounding area were constructed, disturbing these past agricultur al uses (in the 1960’s and 1970’s). Thus, due to the highly disturbed and developed condition of this area, it is the opinion of Michael Baker that the presence of residual herbicide/pesticide contamination in on-site surface soils is unlikely and no REC has resulted in this regard.

6.1.3 CURRENT ADJOINING PROPERTIES

Adjoining uses include transportation, commercia l, and water-related uses (Santa Ana River).

During a preliminary observation of adjoining properties from public thor oughfares, no visible or physical evidence was observed to suggest that a surface release of petroleum-based or hazardous materials or waste have recently occu rred. No unusual or suspicious materials handling or storage practices were observed with respect to adjoining properties. Further, no adjoining properties are listed in a regulatory da t a b a s e , a s s e a r c h e d b y E D R , i n d i c a t i v e o f a release. The following is a discussion of Mi chael Baker’s findings pertaining to adjoining properties reported to have UST:

6.1.3.1 2211 West Orangewood Avenue

The property located at 2211 West Orangewood Avenue was listed for having an UST. However, based on the files reviewed at the OCHCA, this address was reported incorrectly by EDR and should be 2211 East Orangewood Avenue, which does no t adjoin the subject site. As this site is not adjoining the subject site, but is actually situated greater than 1,400 feet west of the subject site, this property is no longer of concern. It is the opinion of Michael Baker that this property has not resulted in a REC.

6.1.3.2 2400 East Orangewood Avenue

According to EDR, the adjoining property 2400 East Orangewood Avenue (Fire Station Training Center) had a historical UST containing diesel fuel. EDR has reported this tank as removed. No UST files are maintained by the OCHCA for this facilty. Further, no releases have been reported Section 6.0 | Evaluation

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by EDR. Thus, based on the information reviewed as part of this Phase I ESA, it is Michael Baker’s opinion that this adjoining property has not resulted in a REC at the time of this Phase I ESA.

6.1.4 PAST ADJOINING USES

Past adjoining properties consisted of vacant land and agricultural uses. These past adjoining properties were not identified on any of the standard environmental record sources or other files indicative of a release. No known corrective ac tion, restoration, remediation has been planned, is currently taking place, or has been completed on past properties adjoining the subject site. Past properties adjoining the subjec t site have not been under investigation for violation of any environmental laws, regulations, or standards, as identified in the databases reported by EDR.

Therefore, it is Michael Baker’s opinion that past adjoining properties have not resulted in a REC at the time of this Phase I ESA.

6.1.5 CURRENT AND PA ST ADJACENT USES

Current and past adjacent uses consist of vacant land, agricultural, commercial, residential, and transportation uses. Multiple adjacent properties were listed in multiple regulatory databases involving hazardous materials. However, based on the information reviewed as part of this Phase I ESA, no reported adjacent regulatory prop erties have been identified that also present a potential concern to groundwater underlying th e subject site, other than the properties listed below. Apart from the properties listed below, the reported adjacent regulatory properties are considered to have a low potential of affecting the subject site for one or more of the following reasons: distance from the subject site, direction of anticipated groundwater flow, site status, and/or no contamination has been reported.

700 North Eckhoff Street: This property reported a release to soil and was closed by the RWQCB on November 10, 2009. However, the case clos ure letter identified groundwater contamination at this property (which is only 588 feet up-gradient of the subject site) as a result of the off-site property 2023 West Collins Street (which is situated approximately 2,420 feet up gradient from the subject site). Based on this information, it is the opinion of Michael Baker that the facility located at 700 North Eckhoff Street has not resulted in a REC on the subject site.

2023 Collins Street: This off-site property (situated approximately 2,420 feet up gradient from the subject site) reported a release of TCA, PCE, and TCE to soil and groundwater. A VES was installed in 1996 and since 1996, approximately 2,000 pounds of VOCs have been removed through this process. As VES was no longer ef fective in removing residual VOCs from the soil and the site being consistent with the RWQCB’s low threat policy, this ca se was closed on April 7, 2005.

Section 6.0 | Evaluation

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Based on the files reviewed as part of 700 North Eckhoff Street, groundwater down-gradient this property as far as 6,500 feet re main impacted by this release (although case closure has been achieved). As the subject site is located within this impact area, it is the opinion of Michael Baker that a REC as a result of groundwater contamination exists.

6.1.7 DATA GAPS

A data gap is a lack of or inability to obtain information required by the ASTM E 1527-13 Standard Practice despite good faith efforts by the Environmental Professional to gather such information.

Data gaps may result from incompleteness in any of the activities required by this practice, including but not limited to site reconnaissance (for example, an inability to conduct the site visit) and interviews (for example, an inability to intervie w the key site manager, regulatory officials, etc.). A data gap by itself is not inherently significant. For example, if a property’s historical use is not identified back to 1940 because of data failure, but the earliest source shows that the property was undeveloped, this data gap by itself would not be significant. A data gap is only significant if other information and/or professi onal experience raises reasonable concerns involving the data gap. For example, if a building on the property is inaccessible during the site visit, and the Environmental Professional’s ex perience indicates that such a building often involves activity that leads to an REC, the inability to inspect the building would be a significant data gap warranting comment.

No significant data gaps were noted during the course of the Phase I ESA. Refer to Section 6.3, Limiting Conditions/Deviations, below.

6.2 CONCLUSIONS

Michael Baker has performed a Phase I ESA in conformance with the scope and limitations of ASTM E 1527-13 Standard Practice of the Orangew ood Avenue Improvements project, located within the cities of Anaheim and Orange, Orang e County, California, the subject site. Any exceptions to, or deletions from, this practice are described in Section 6.3, Limiting Conditions/Deviations, of this Phase I ESA. This Phase I ESA has revealed evidence of the following RECs in connection with the subject site:

Aerially Deposited Lead: Based on historical aerial photographs and USGS topographic maps, SR-57 was constructed in 1977. The potential for lead contamination to exist within exposed soils Section 6.0 | Evaluation

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on-site due to aerially deposited lead is likely. It is Michael Baker’s opinion that there is a REC on the subject site as a result of aerially deposited lead.

Groundwater Contamination: The adjacent property located at 2023 Collins Street (approximately 2,420 feet up gradient of the subject site) was found to have groundwater contamination extending to a maximum distance of 6,500 feet down gradient, which includes the subject site and areas of propose ROW acquisition. As such, it is the opinion of Michael Baker that a REC has resulted via groundwater from th e adjacent regulatory property located at 2023 Collins Street. It is acknowledged that groundwater is anticipated to be greater than 80 feet below ground surface.

6.3 LIMITING CONDITIONS / DEVIATIONS

No interviews with current/past property owners or local government officials were conducted.

Based on available information reviewed as part of this Phase I ESA, past and current on-site uses appeared to historically consist of the Santa Ana River, past agricultural uses, and transportation uses. No evidence to suggest other uses was noted. Based on the historical documentation reviewed, it is Michael Baker’s opinion that these interviews would not increase the knowledge of the Environmental Professional such that the conclusions of this Phase I ESA would change.

Thus, it is the opinion of Michael Baker that this deviation is not a significant data gap.

No additional scope items, or items outside of the scope of a Phase I ESA E 1527-13 Standard Practice, were conducted as part of this Phase I ESA.

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SECTION 7.0

REFERENCES

Anthony J. Buonicore, Methodology for Identifying the Area of Concern Around a Property Potentially Impacted by Vapor Migration from Nearby Contaminated Sources , Paper 2011-A-301-AWMA, June 2011.

ASTM International, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process, Designation: E 1527-13.

City of Anaheim, General Plan for the City of Anaheim California, May 2004.

City of Orange, Orange General Plan, March 2010.

County of Orange Health Care Agency, File Review Request, sent on August 28, 2017.

Department of Conservation, Division of O il, Gas & Geothermal Resources, Well Finder Application, http://www.conservation.ca.gov/dog/Pages/Wellfinder.aspx, accessed on August 30, 2017.

Environmental Data Resources, Inc., Certified Sanborn Map Report, dated August 22, 2017.

Environmental Data Resources, Inc., EDR City Directory Image Report, dated August 23, 2017.

Environmental Data Resources, Inc., EDR Aerial Photo Decade Package, dated August 23, 2017.

Environmental Data Resources, Inc., EDR Historical Topo Map Report, dated August 22, 2017.

Environmental Data Resources, Inc., EDR Radius Map Report with GeoCheck , dated August 22, 2017.

Federal Emergency Management Agency, National Flood Insurance Program, Flood Insurance Rate Map, Map Number 06059C0142J, revised December 3, 2009.

Fire Review at the Orange County Health Care Agency, conducted on October 3, 2017.

Site Visit, conducted on September 13, 2017.

Section 7.0 | References

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The Planning Center, The Revised Platinum Triangle Expansion Project Subsequent Environmental Impact Report No. 339, August 2010.

United States Department of Agriculture, Natural Resources Conservation Service, Web Soil Survey, http://websoilsurvey.nrcs.usda.gov/app/, accessed August 28, 2017.

United States Environmental Protection Agency, Map of Radon Zones, dated 1993.

USGS Topographic Quadrangle, Anaheim Quadrangle, California, dated 2015.

APPENDICES

APPENDIX A:

ASTM TERMINOLOGY

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TERMINOLOGY

The following definitions and descriptions of terms are from the ASTM E1527 -13 Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process.

Abandoned property – property that can be presumed to be deserted, or an intent to relinquish possession or control can be inferred from the general disrepair or lack of activity thereon such that a reasonable person could believe that there was an intent on the part of the current owner to surrender rights to the property.

Activity and use limitations – legal or physical restrictions or limitations on the use of, or access to, a site or facility: (1) to reduce or eliminate potential exposure to hazardous substances or petroleum products in the soil, soil vapor, groundwater, and/or surface water on the property, or (2) to prevent activities that could interfere with the effectiveness of a response action, in order to ensure maintenance of a condition of no significant risk to public health or the environment. These legal or physical restrictions, which may include institutional and/or engineering controls, are intended to prevent adverse impacts to individuals or populations that may be exposed to hazardous substances and petroleum products in the soil, soil vapor, groundwater, and/or surface water on the property. See Note 1.

NOTE 1 — the term AUL is taken from Guide E2091 to include both legal (that is, institutional) and physical (that is, engineering) controls within its scope. Other agencies, organizations, and jurisdictions may define or utilize these terms differently (for example, EPA and California do not include physical controls within their definitions of “institutional controls.” Department of Defense and International County/City Management Association use “Land Use Controls.” The term ‘land use restrictions” is used but not defined in the Brownfields Amendments).

Actual knowledge – the knowledge actually possessed by an individual who is a real person, rather than an entity. Actual knowledge is to be disting uished from constructive knowledge that is knowledge imputed to an individual or entity.

Adjoining properties – any real property or properties the border of which is contiguous or partially contiguous with that of the property, or that would be contiguous or partially contiguous with that of the property but for a street, road, or other public thoroughfare separating them.

Appendix A | ASTM Terminology

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Aerial photographs – photographs taken from an aerial platform with sufficient resolution to allow identification of development an d activities of areas encompassing the property.

Aerial photographs are often available from government agencies or private collections unique to a local area.

All appropriate inquiry – that inquiry constituting “all appropriate inquiry into the previous ownership and uses of the property consistent with good commercial or customary practice” as defined in CERCLA . 42 U.S.C. §9601(35)(B), that will qualify a party to a commercial real estate transaction for one of threshold criteria for satisfying the LLP s to CERCLA liability (42 U.S.C. §9601(35)(A) & (B), §9607(b)(3), §(9607(q); and §9607(r)), assuming compliance with other elements of the defense.

Approximate minimum search distance – the area for which records must be obtained and reviewed pursuant to Section 8 subject to the limitations provided in that section. This may include areas outside the property and shall be measured from the nearest property boundary. This term is used in lieu of radius to include irregularly shaped properties.

Bona fide prospective purchaser liability protection – (42 U.S.C. §9607(r) – a person may qualify as a bona fide prospective purchaser if, among other requirements, such person made “all appropriate inquiries into the previous ownership and uses of the facility in accordance with generally accepted good commercial and customary standards and practices.” Knowledge of contamination resulting from all appropriate inquiry would not generally preclude this liability protection. A person must make all appropriate inquiri es on or before the date of purchase. The facility must have been purchased after January 11, 2002.

Brownfields Amendments – amendments to CERCLA pursuant to the Small Business Liability Relief and Brownfields Revitalization Act, Pub. L. No. 107-118 (2002), 42 U.S.C. §§9601 et. seq.

Building department records – those records of the local government in which the property is located indicating permission of the local government to construct, alter, or demolish improvements on the property. Often building department records are located in the building department of a municipality or county.

Business environmental risk – a risk which can have a material environmental or environmentally-driven impact on the business associated with the current or planned use of a parcel of commercial real estate, not necessarily limited to those environmental issues required to be investigated in this practice. Consideration of business Appendix A | ASTM Terminology

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environmental risk issues may involve addressing one or more non-scope considerations, some of which are identified in Section 13.

Commercial real estate – any real property except a dwelling or property with no more than four dwelling units exclusively for residential use (except that a dwelling or property with no more than four dwelling units exclusively for residential use is included in this term when it has a commercial function, as in the building of such dwellings for profit). This term includes but is not limited to undeveloped real property and real property used for industrial, retail, office, agricultural, other commercial, medical, or educational purposes:
property used for residential purposes that has more than four residential dwelling units; and property with no more than four dwelling units for residential use when it has a commercial function, as in the building of such dwellings for profit.

Commercial and real estate transaction – a transfer of title to or possession of real property or receipt of a security interest in real property, except that it does not include transfer of title to or possession of real property or the receipt of a security interest in real property or the receipt of a security interest in real property with respect to an individual dwelling or building containing fewer than five dwelling units, nor does it include the purchase of a lot or lots to construct a dwelling for occupancy by a purchaser, but a commercial real estate transaction does include real property purchased or leased by persons or entities in the business of building or developing dwelling units.

Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) – the list of sites compiled by EPA that EPA has investigated or is currently investigating for potential hazardous substance contamination for possible inclusion on the National Priorities List.

Construction debris – concrete, brick, asphalt, and other such building materials discarded in the construction of a building or other improvement to property.

Contaminated public wells – public wells used for drinking water that have been designated by a government entity as contaminated by hazardous substances (for example, chlorinated solvents), or as having water unsafe to drink without treatment.

Contiguous property owner liability protection – (42 U.S.C. §9607(q) – a person may qualify for the contiguous property owner liability protection if, among other require ments, such person owns real property that is contiguous to, and that is or may be contaminated by hazardous substances from other real property that is not owned by that person.

Furthermore, such person conducted all appropriate inquiries at the time of acquisition of Appendix A | ASTM Terminology

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the property and did not know or have reason to know that the property was or could be contaminated by a release or threatened release from the contiguous property. The all appropriate inquiries must not result in knowledge of contamination. If it does, then such person did “know” or “had reason to know” of contamination and would not be eligible for the contiguous property owner liability protection. See Appendix X1 for the other necessary requirements that are beyond the scope of this practice.

Controlled recognized environmental condition – a recognized environmental condition resulting from a past release of hazardous substances or petroleum products that has been addressed to the satisfaction of the applicable regulatory authority (fo r example, as evidenced by the issuance of a no further action letter or equivalent, or meeting risk-based criteria established by regulatory authority), with hazardous substances or petroleum products allowed to remain in place subject to the implementati on of required controls (for example, property use restrictions, activity and use limitations, institutional controls, or engineering controls). (See Note 2). A condition considered by the environmental professional to be controlled recognized environmental condition shall be listed in the findings section of the Phase I Environmental Site Assessment report, and as a recognized environmental condition in the conclusions section of the Phase I Environmental Site Assessment report. (See Note 3).

Note 2 — For example, if a leaking underground storage tank has been cleaned up to a commercial use standard, but does not meet unrestricted residential cleanup criteria, this would be considered a controlled recognized environmental condition. The “control” is r epresented by the restriction that the property use remains commercial.

Note 3 — A condition identified as a controlled recognized environmental condition does not imply that the environmental professional has evaluated or confirmed the adequacy, implementation, or continued effectiveness of the required control that has been, or is intended to be implemented.

CORRACTS list – a list maintained by EPA of hazardous waste treatment, storage, or disposal facilities and other RCRA -regulated facilities (due to past interim status or storage of hazardous waste beyond 90 days) that have been notified by the U.S. Environmental Protection Agency to undertake corrective action under RCRA. The CORRACTS list is a subset of the EPA database that manages RCRA data.

Data failure – a failure to achieve the historical research objectives in 8.3.1 through 8.3.2.2 even after reviewing the standard historical sources 8.3.4.1 through 8.3.4.8 that are reasonably ascertainable and likely to be useful. Data failure is one type of data gap. See 8.3.2.3.

Appendix A | ASTM Terminology

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Data gap – a lack of or inability to obtain information required by this practice despite good faith efforts by the environmental professional to gather such information. Data gaps may result from incompleteness in any of the activities required by this practice, including, but not limited to site reconnaissance (for example, an inability to conduct the site visit), and interviews (for example, an inability to interview the key site manager, regulatory officials, etc.). See 12.7.

Demolition debris – concrete, brick, asphalt, and other such building materials discarded in the demolition of a building or other improvement to property.

De minimis condition – a condition that generally does not present a threat to human health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies. Conditions determined to be de minimis conditions are not recognized environmental conditions nor controlled recognized environmental conditions.

Drum – a container (typically, but not necessarily, holding 55 gal (208 L) of liquid) that may be used to store hazardous substances or petroleum products.

Dry wells – underground areas where soil has been removed and replaced with pea gravel, coarse sand, or large rocks. Dry wells are used for drainage, to control storm runoff, for the collection of spilled liquids (intentional and non-intentional) and wastewater disposal (often illegal).

Due diligence – the process of inquiring into the environmental characteristics of a parcel of commercial real estate or other conditions, usually in connection with a commercial real estate transaction. The degree and kind of due diligence vary for different properties and differing purposes. See Appendix X1.

Dwelling – structure or portion thereof used for residential habitation.

Engineering controls (EC) – physical modifications to a site or facility (for example, capping, slurry walls, or point of use water treatment) to reduce or eliminate the potential for exposure to hazardous substances or petroleum products in the soil or groundwater on the property. Engineering controls are a type of activity and use limitation (AUL).

Environment – environment shall have the same meaning as the definition of environment in CERCLA 42 U.S.C. § 9601 (8). For additional background information, see Legal Appendix (Appendix X1) to section XI. 1.1 “Releases and Threatened Release.” Appendix A | ASTM Terminology

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Environmental compliance audit – the investigative process to determine if the operations of an existing facility are in compliance with applicable environmental laws and regulations.

This term should not be used to describe this practice, although an environmental compliance audit may include an environmental site assessment or, if prior audits are available, may be part of an environmental site assessment.

Environmental lien – a charge, security, or encumbrance upon title to a property to secure the payment of a cost, damage, debt, obligation, or duty arising out of response actions, cleanup, or other remediation of hazardous substances or petroleum products upon a property, including (but not limited to) liens imposed pursuant to CERCLA 42 U.S.C. §§9607(1) & 9607(r) and similar state or local laws.

Environmental professional – a person meeting the education, training, and experience requirements as set forth in 40 CFR §312.10(b). For the convenience of the reader, this section is reprinted in Appendix X2. The person may be an independent contractor or an employee of the user.

Environmental site assessment (ESA) – the process by which a person or entity seeks to determine if a particular parcel of real property (including improveme nts) is subject to recognized environmental conditions. At the option of the user, an environmental site assessment may include more inquiry than that constituting all appropriate inquiries or, if the user is not concerned about qualifying for the LLPs, l ess inquiry than that constituting all appropriate inquiries. An environmental site assessment is both different from and often less rigorous than an environmental compliance audit.

ERNS list – EPA’s emergency response notification system list of reporte d CERCLA hazardous substance releases or spills in quantities greater than the reportable quantity, as maintained at the National Response center. Notification requirements for such releases or spills are codified in 40 CFR Parts 302 and 335.

Federal Register (FR) – publication of the United States government published daily (except for federal holidays and weekends) containing all proposed and final regulations and some other activities of the Federal Government. When regulations become final, they are included in the Code of Federal Regulations (CFR), as well as published in the Federal Register.

Fill dirt – dirt, soil, sand, or other earth, that is obtained off -site, that is used to fill holes or depressions, create mounds, or otherwise artificially change the grade or elevation or real Appendix A | ASTM Terminology

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property. It does not include material that is used in limited quantities for normal landscaping activities.

Fire insurance maps – maps produced for private fire insurance map companies that indicate uses of properties at specified dates and that encompass the property. These maps are often available at local libraries, historical societies, private resellers, or from the map companies who produced them.

Good faith – the absence of any intention to seek an unfair advantage or to defraud another party; an honest and sincere intention to fulfill one’s obligations in the conduct or transaction concerned.

Hazardous substance – a substance defined as a hazardous substance pursuant to CERCLA 42 U.S.C. §9601(14), as interpreted by EPA regulations and the courts: “(A) any substance designated pursuant to section 1321(b)(2)(A) of Title 33, (B) any element, compound, mixture, solution, or substance designated pursuant to section 9602 of this title, (C) any hazardous waste having the characteristics identified under or listed pursuant to section 3001 of the Resource Conservation and Recovery Act of 1976 (RCRA), as amended, (42 U.S.C. §6921) (but not including any waste the regulation of which under RCRA (42 U.S.C. §§6901 et seq.) has been suspended by Act of Congress, (D) any toxic pollutant listed under section 1317(a) of Title 33, (E) any hazardous air pollutant listed under section 112 of the Clean Air Act (42 U.S.C. §7412), and (F) any imminently hazardous chemical substance or mixture with respect to which the Administrator (of EPA) has taken action pursuant to section 2606 of Title 15. The term does not include petroleum, including crude oil or any fraction thereof which is not otherwise specifically listed or designated as a hazardous substance under subparagraphs (A) through (F) of this paragraph, and the term does not include natural gas, natural gas liquids, liquefied natural gas, or synthetic gas usable for fuel (or mixtures of natural gas and such synthetic gas).” (See Appendix X1.)

Hazardous waste – any hazardous waste having the characteristics identified under or listed pursuant to section 3001 of RCRA, as amended, (42 U.S.C. §6921) (but not including any waste the regulation of which under RCRA (42 U.S.C. §§6901-6992(k) has been suspended by Act of Congress). RCRA is sometimes also identified as the Solid Waste Disposal Act.

RCRA defines a hazardous waste, at 42 U.S.C. §6903, as: “a solid waste, or combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may – (A) cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or (B) Appendix A | ASTM Terminology

Orangewood Avenue Improvements Phase I ESA | A-8
pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed.”

Hazardous waste/contaminated sites – sites on which a release has occurred, or is suspected to have occurred, of any hazardous substance, hazardous waste, or petroleum products, and that release or suspected release has been reported to a government entity.

Historical recognized environmental condition – a past release of any hazardous substances or petroleum products that has occurred in connection with the property and has been addressed to the satisfaction of the applicable regulatory authority or meeting unrestricted use criteria established by a regulatory authority, without subjecting the property to any required controls (for example, property use restrictions, activity and use limitations, institutional controls, or engineering controls). Before calling the past release a historical recognized environmental condition, the environmental professional must determine whether the past release is a recognized environmental condition at the time the Phase I Environmental Site Assessment is conducted (for example, if there has been a change in the regulatory criteria). If the EP considers the past release to be a recognized environmental condition at the time the Phase I ESA is conducted, the condition shall be included in the conclusions section of the report as a recognized environmental condition.

IC/EC registries – databases of institutional controls or engineering controls that may be maintained by a federal, state or local environmental agency for purposes of tracking sites that may contain residual contamination and AULs. The names for these may vary from program to program and state to state, and include terms such as Declaration of Environmental Use Restriction database (Arizona), list of “deed restrictions” (California), environmental real covenants list (Colorado), brownfields site list (Indiana, Missouri, Pennsylvania), and the Pennsylvania Activity and Use Limitation (PA AUL) Registry.

Innocent landowner defense – (42 U.S.C. §§9601(35) and 9607(b)(3)) – a person may qualify as one of three types of innocent landowners: (i) a person who “did not know and had no reason to know” that contamination existed on the property at the time the purchaser acquired the property; (ii) a government entity which acquired the property by escheat, or through any other involuntary transfer or acquisition, or through the exercise of eminent domain authority by purchase or condemnation; and (iii) a person who “acquired the facility by inheritance or bequest.” To qualify for the first type of innocent landowner defense, such person must have made all appropriate inquiries on or before the date of purchase. Furthermore, the all appropriate inquiry must not have resulted in knowledge of the contamination. If it does, then such person did “know” or “had reason to know” of contamination and would not be eligible for the innocent landowner defense. See Appendix A | ASTM Terminology

Orangewood Avenue Improvements Phase I ESA | A-9
Appendix X1 for the other necessary requirements that are beyond the scope of this practice.

Institutional controls (IC) – a legal or administrative restriction (for example, “deed restrictions,” restrictive covenants, easements, or zoning) on the use of, or access to, a site or facility to (1) reduce or eliminate potential exposure to hazardous substances or petroleum products in the soil or groundwater on the property, or (2) to prevent activities that could interfere with the effectiveness of a response action, in order to ensure maintenance of a condition of no significant risk to public health or the environment. An institutional control is a type of Activity and Use Limitation (AUL).

Interviews – those portions of this practice that are contained in Section 10 and 11 thereof and address questions to be asked of past and present owners, operators, and occupants of the property and questions to be asked of local government officials.

Key site manager – the person identified by the owner or operator of a property as having good knowledge of the uses and physical characteristics of the property. See 10.5.1.

Landfill – a place, location, tract of land, area, or premises used for the disposal of solid wastes as defined by state solid waste regulations. The term is synonymous with the term solid waste disposal site and is also known as a garbage dump, trash dump, or similar term.

Landowner Liability Protections (LLPs) – landowner liability protections under CERCLA; these protections include the bona fide prospective purchaser liability protection, contiguous property owner liability protection, and innocent landowner defense from CERCLA liability. See 42 U.S.C. §§9601(35)(A), 9601(40), 9607(b), 9607(q), 9607(r).

Local government agencies – those agencies of municipal or county government having jurisdiction over the property. Municipal and county government agencies include but are not limited to cities, parishes, townships, and similar entities.

Local street directories – directories published by private (or sometimes government) sources that show ownership, occupancy, and/or use of sites by reference to street addresses.

Often local street directories are available at libraries, or historical societies, and/or local municipal offices. See 8.3.4.6 of this practice.

LUST sites – state lists of leaking underground storage tank sites. RCRA gives EPA and states, under cooperative agreements with EPA, authority to clean up releases from UST systems or require owners and operators to do so. (42 U.S.C. §6991b).

Appendix A | ASTM Terminology

Orangewood Avenue Improvements Phase I ESA | A-10

Major occupants – those tenants, subtenants, or other persons or entities each of which uses at least 40% of the leasable area of the property or any anchor tenant when the property is a shopping center.

Material safety data sheet (MSDS) – written or printed material concerning a hazardous substance which is prepared by chemical manufacturers, importers, and employers for hazardous chemicals pursuant to OSHA’s Hazard Communication Standard, 29 C.F.R. §1910.1200.

Material threat – A physically observable or obvious threat which is reasonably likely to lead to a release that, in the opinion of the environmental professional, is threatening and might result in impact to public health or the environment. An example migh t include an aboveground storage tank system that contains a hazardous substance and which shows evidence of damage. The damage would represent a material threat if it is deemed serious enough that it may cause or contribute to tank integrity failure with release of contents to the environment.

Migrate/migration – for the purposes of this practice, “migrate” and “migration” refers to the movement of hazardous substances or petroleum products in any form, including, for example, solid and liquid at the surface or subsurfaces, and vapor in the subsurface. See Note 4.

Note 4 — Vapor migration in the subsurface is described in Guide E2600; however, nothing in this practice should be construed to require application of the Guide E2600 standard to achieve compliance with all appropriate inquiries.

National Contingency Plan (NCP) – the National Oil and Hazardous Substances Pollution Contingency Plan, found at 40 C.F.R. Part 300, that is the EPA’s blueprint on how hazardous substances are to be cleaned up pursuant to CERCLA.

National Priorities List (NPL) – list compiled by EPA pursuant to CERCLA 42 U.S.C. §9605(a)(8)(B) of properties with the highest priority for cleanup pursuant to EPA’s Hazard Ranking System. See 40 C.F.R. Part 300.

Obvious – that which is plain or evident; a condition or fact that could not be ignored or overlooked by a reasonable observer while visually or physically observing the property.

Appendix A | ASTM Terminology

Orangewood Avenue Improvements Phase I ESA | A-11
Occupants – those tenants, subtenants, or other persons or entities using the property or a portion of the property.

Operator – the person responsible for the overall operation of a facility.

Other historical sources – any source or sources other than those designated in Sections 8.3.4.1 through 8.3.4.8 that are credible to a reasonable person and that identify past uses of the property. The term includes, but is not limited to: miscellaneous maps, newspaper archives, internet sites, community organizations, local libraries, historical societies, current owners or occupants of neighboring properties, and records in the files and/or personal knowledge of the property owner and/or occupants. See 8.3.4.9.

Owner – generally the fee owner of record of the property.

Petroleum exclusion – the exclusion from CERCLA liability provided in 42 U.S.C. §9601(14), as interpreted by the courts and EPA: “The term (hazardous substance) does not include petroleum, including crude oil or any fraction thereof which is not otherwise specifically listed or designated as a hazardous substance under subparagraphs (A) through (F) of this paragraph, and the term does not include natural gas, natural gas liquids, liquefied natural gas, or synthetic gas usable for fuel (or mixtures of natural gas and such synthetic gas).”

Petroleum products – those substances included within the meaning of the petroleum exclusion to CERCLA, 42 U.S.C. §9601(14), as interpreted by the courts and EPA, that is: petroleum, including crude oil or any fraction thereof which is not otherwise specifically listed or designated as a hazardous substance under Subparagraphs (A) through (F) of 42 U.S.C. §9601(14), natural gas, natural gas liquids, liquefied natural gas, and synthetic gas usable for fuel (or mixtures of natural gas and such synthetic gas). (The word fraction refers to certain distillates of crude oil, including gasoline, kerosene, diesel oil, jet fuels, and fuel oil, pursuant to Standard Definitions of Petroleum Statistics. )

Phase I Environmental Site Assessment – the process described in this practice.

Physical setting sources – sources that provide information about the geologic, hydrogeologic, hydrologic, or topographic characteristics of a property. See 8.2.4.

Pits, ponds, or lagoons – man-made or natural depressions in a ground surface that are likely to hold liquids or sludge containing hazardous substances or petroleum products. The likelihood of such liquids or sludge being present is determined by evidence of factors Appendix A | ASTM Terminology

Orangewood Avenue Improvements Phase I ESA | A-12
associated with the pit, pond, or lagoon, in cluding, but not limited to, discolored water, distressed vegetation, or the presence of an obvious wastewater discharge.

Practically reviewable – information that is practically reviewable means that the information is provided by the source in a manner and in a form that, upon examination, yields information relevant to the property without the need for extraordinary analysis of irrelevant data. The form of the information shall be such that the user can review the records for a limited geographic area. Records that cannot be feasibly retrieved by reference to the location of the property or a geographic area in which the property is located are not generally practically reviewable. Most databases of public records are practically reviewable if they can be obtained from the source agency by the county, city, zip code, or other geographic area of the facilities listed in the record system. Records that are sorted, filed, organized, or maintained by the source agency only chronologically are not generally practically reviewable. Listings in publicly available records which do not have adequate address information to be located geographically are not generally considered practically reviewable. For large databases with numerous records (such as RCRA haza rdous waste generators and registered underground storage tanks), the records are not practically reviewable unless they can be obtained from the source agency in the smaller geographic area of zip codes. Even when information is provided by zip code for some large databases, it is common for an unmanageable number of sites to be identified within a given zip code. In these cases, it is not necessary to review the impact of all of the sites that are likely to be listed in any given zip code because that information would not be practically reviewable. In other words, when so much data is generated that it cannot be feasibly reviewed for its impact on the property, it is not practically reviewable.

Property – the real property that is the subject of the environmental site assessment described in this practice. Real property includes buildings and other fixtures and improvements located on the property and affixed to the land.

Property tax files – the files kept for property tax purposes by the local jurisdiction where the property is located and may include records of past ownership, appraisals, maps, sketches, photos, or other information that is reasonably ascertainable and pertaining to the property. See 8.3.4.3.

Publicly available – information that is publicly available means that the source of the information allows access to the information by anyone upon request.

Appendix A | ASTM Terminology

Orangewood Avenue Improvements Phase I ESA | A-13
RCRA generators – those persons or entities that generate hazardous wastes, as defined and regulated by RCRA.

RCRA generators list – list kept by EPA of those persons or entities that generate hazardous wastes as defined and regulated by RCRA.

RCRA TSD facilities – those facilities on which treatment, storage, and/or disposal of hazardous wastes takes place, as defined and regulated by RCRA.

RCRA TSD facilities list – list kept by EPA of those facilities on which treatment, storage, and/or disposal of hazardous wastes takes place, as defined and regulated by RCRA.

Reasonably ascertainable – information that is (1) publicly available, (2) obtainable from its source within reasonable time and cost constraints, and (3) practically reviewable.

Recognized environmental conditions – the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment. De minimis conditions are not recognized environmental conditions.

Recorded land title records – records of historical fee ownership, which may include leases, land contracts, and AULs on or of the prop erty recorded in the place where land title records are, by law or custom, recorded for the local jurisdiction in which the property is located. (Often such records are kept by a municipal or county recorder or clerk.) Such records may be obtained from title companies or directly from the local government agency.

Information about the title to the property that is recorded in a U.S. district court or any place other than where land title records are, by law or custom, recorded for the local jurisdiction in which the property is located, are not considered part of recorded land title records. See 8.3.4.4.

Records of emergency release notifications EPCRA – (42 U.S.C. §11004) – requires operators of facilities to notify their local emergency planning commi ttee (as defined in EPCRA) and state emergency response commission (as defined in EPCRA) and state emergency response commission (as defined in EPCRA) of any release beyond the facility’s boundary of any reportable quantity of any extremely hazardous substance. Often the local fire department is the local emergency planning committee. Records of such notifications are “Records of Emergency Release Notifications” (42 U.S.C. 11004).

Appendix A | ASTM Terminology

Orangewood Avenue Improvements Phase I ESA | A-14
Records review – that part that is contained in Section 8 of this practice which addresses records shall or may be reviewed.

Release – a release of any hazardous substance or petroleum product shall have the same meaning as the definition of “release” in CERCLA 42 U.S.C. § 9601(22)). For additional background information, see Legal Appendix (Appendix X1) to X1.1.1 “Releases and Threatened Release.”

Report – the written report prepared by the environmental professional and constituting part of a “Phase I Environmental Site Assessment,” as required by this practice.

Site reconnaissance – that part that is contained in Section 9 of this practice and addresses what should be done in connection with the site visit. The site reconnaissance includes, but is not limited to, the site visit done in connection with such a Phase I Environmental Site Assessment.

Site visit – the visit to the property during which observations are made constituting the site reconnaissance section of this practice.

Solid waste disposal site – a place, location, tract of land, area, or premises used for the disposal of solid wastes as defined by state solid waste regulations. The term is synonymous with the term landfill and is also known as a garbage dump, trash dump, or similar term.

Solvent – a chemical compound that is capable of dissolving another substance and may itself be a hazardous substance, used in a number of manufacturing/industrial processes including but not limited to the manufacture of paints and coatings for industrial and household purpose, equipment clean -up, and surface degreasing in metal fabricating industries.

Standard environmental record sources – those records specified in Section 8.2.1.

Standard historical sources – those sources of information about the history of uses of property specified in Section 8.3.4.

Standard physical setting source – a current (USGS 7.5 Minute Topographic Map (if any) showing the area on which the property is located.

Standard practice – the activities set forth in this practice.

Appendix A | ASTM Terminology

Orangewood Avenue Improvements Phase I ESA | A-15
Standard sources – sources of environmental, physical setting, or historical records specified in section 8 of this practice.

State registered USTs – state lists of underground storage tanks required to be registered under Subtitle I, Section 9002 of RCRA.

Sump – a pit, cistern, cesspool, or similar receptacle where liquids drain, collect, or are stored.

TSD facility – treatment, storage, or disposal facility (see RCRA TSD facilities).

Underground injection – the emplacement or discharge of fluids into the subs urface by means of a well, improved sinkhole, sewage drain hole, subsurface fluid distribution system or other system, or groundwater point source.

Underground storage tank (UST) – any tank, including underground piping connected to the tank, that is or has been used to contain hazardous substances or petroleum products and the volume of which is 10% or more beneath the surface of the ground.

User – the party seeking to use Practice E1527 to complete and environmental site assessment of the property. A user may include, without limitation, a potential purchaser of property, a potential tenant of property, an owner of property, a lender, or a property manager. The user has specific obligations for completing a successful application of this practice as outlined in Section 6.

USGS 7.5 Minute Topographic Map – the map (if any) available from or produced by the United States Geological Survey entitled “USGS 7.5 Minute Topographic Map,” and showing the property.

Visually and/or physically observed – during a site visit pursuant to this practice, this term means observations made by vision while walking through a property and the structures located on it and observations made by the sense of smell, particularly observations of noxious or foul odors. The term “walking through” is not meant to imply that disabled persons who cannot physically walk may not conduct a site visit; they may do so by the means at their disposal for moving through the property and the structures located on it.

Wastewater – water that (1) is or has been used in an industrial or manufacturing process, (2) conveys or has convey sewage, or (3) is directly related to manufacturing, processing, or raw materials storage areas at an industrial plant. Wastewater does not include water originating on or passing through or adjacent to a site, such as stormwater flows, that has Appendix A | ASTM Terminology

Orangewood Avenue Improvements Phase I ESA | A-16
not been used in industrial or manufacturing processes, has not been combined with sewage, or is not directly related to manufacturing, processing, or raw materials storag e areas at an industrial plant.

Zoning/land use records – those records of the local government in which the property is located indicating the uses permitted by the local government in particular zones within its jurisdiction. The records may consist of maps and/or written records. They are often located in the planning department of a municipality or county. See 8.3.4.8.

APPENDIX B:

DATABASE RECORDS SEARCHES

FORM-LBC-RG
® k c e h C o e G h t i w t r o p e R ™ p a M s u i d a R R D E e h T 6 Armstrong Road, 4th floor
Shelton, CT 06484
Toll Free: 800.352.0050
www.edrnet.com
Orangewood Avenue Improvements
NA
Orange, CA 92806
Inquiry Number: 5029994.2s
August 22, 2017

SECTION PAGE
Executive Summary ES1
Overview Map 2
Detail Map 3
Map Findings Summary 4
Map Findings 8
Orphan Summary 119
Government Records Searched/Data Currency Tracking GR-1

GEOCHECK ADDENDUM
Physical Setting Source Addendum A-1
Physical Setting Source Summary A-2
Physical Setting SSURGO Soil Map A-6
Physical Setting Source Map A-11
Physical Setting Source Map Findings A-13
Physical Setting Source Records Searched PSGR-1
TC5029994.2s
Thank you for your business.

Please contact EDR at 1-800-352-0050
with any questions or comments.

Disclaimer - Copyright and Trademark Notice
This Report contains certain information obtained from a variety of public and other sources reasonably available to Environmental Data Resources, Inc. It cannot be concluded from this Report that coverage information for the target and surrounding properties does not exist from other sources. NO WARRANTY EXPRESSED OR IMPLIED, IS MADE WHATSOEVER IN CONNECTION WITH THIS REPORT. ENVIRONMENTAL DATA RESOURCES, INC. SPECIFICALLY DISCLAIMS THE MAKING OF ANY SUCH WARRANTIES, INCLUDING WITHOUT LIMITATION, MERCHANTABILITY OR FITNESS FOR A PARTICULAR USE OR PURPOSE. ALL RISK IS ASSUMED BY THE USER. IN NO EVENT SHALL ENVIRONMENTAL DATA RESOURCES, INC. BE LIABLE TO ANYONE, WHETHER ARISING OUT OF ERRORS OR OMISSIONS, NEGLIGENCE,

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Purchaser accepts this Report "AS IS". Any analyses, estimates, ratings, environmental risk levels or risk codes provided in this Report are provided for illustrative purposes only, and are not intended to provide, nor should they be interpreted as providing any facts regarding, or prediction or forecast of, any environmental risk for any property. Only a Phase I Environmental Site Assessment performed by an environmental professional can provide information regarding the environmental risk for any property. Additionally, the information provided in this Report is not to be construed as legal advice.

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TABLE OF CONTENTS

EXECUTIVE SUMMARY
TC5029994.2s EXECUTIVE SUMMARY 1
A search of available environmental records was conducted by Environmental Data Resources, Inc (EDR).

The report was designed to assist parties seeking to meet the search requirements of EPA’s Standards and Practices for All Appropriate Inquiries (40 CFR Part 312), the ASTM Standard Practice for Environmental Site Assessments (E 1527-13) or custom requirements developed for the evaluation of environmental risk associated with a parcel of real estate.

TARGET PROPERTY INFORMATION

ADDRESS
NA
ORANGE, CA 92806

COORDINATES

33.7957810 - 33˚ 47’ 44.81’’Latitude (North):
117.8792310 - 117˚ 52’ 45.23’’Longitude (West):

Zone 11Universal Tranverse Mercator:
418608.1UTM X (Meters):
3739666.5UTM Y (Meters):
148 ft. above sea levelElevation:

USGS TOPOGRAPHIC MAP ASSOCIATED WITH TARGET PROPERTY
5641294 ANAHEIM, CATarget Property Map:
2012Version Date:
5641308 ORANGE, CAEast Map:
2012Version Date:

AERIAL PHOTOGRAPHY IN THIS REPORT
20140513, 20140514Portions of Photo from:

USDASource:
5029994.2s Page 2
39 THE CITY PLACE NORTH 3745 WEST CHAPMAN AV ENVIROSTOR Lower 4619, 0.875, WSW 38 ITASCO 2211 EAST HOWELL STR ENVIROSTOR, SLIC Higher 4261, 0.807, NNW 37 CALIFORNIA CUSTOM SH 1800 TALBOT WAY RCRA-SQG, ENVIROSTOR, FINDS, ECHO, EMI, HAZNET,... Higher 3880, 0.735, WNW 36 INDEPENDENT FORGE CO 692 N BATAVIA ST RCRA-SQG, ENVIROSTOR, FINDS, ECHO, NPDES, WDS Higher 3860, 0.731, ENE 35 RUNNING SPRINGS ELEM 8670 RUNNING SPRINGS ENVIROSTOR, SCH Higher 3349, 0.634, SE 34 LAMCOR INC 2025 ORANGEWOOD LUST, HIST CORTESE Lower 2551, 0.483, West 33 STATEK CORP. 512 N. MAIN STREET ENVIROSTOR, EMI Higher 2483, 0.470, East H32 INLAND SPECIALTIES C 2023 WEST COLLINS AV ENVIROSTOR, SLIC Higher 2441, 0.462, NNE H31 INLAND SPECIALTIES C 2023 W COLLINS AVE SEMS-ARCHIVE, RCRA-SQG, HAZNET, HIST CORTESE Higher 2441, 0.462, NNE H30 VOC INVESTIGATION 2033 COLLINS Cortese, ENF, HIST CORTESE Higher 2381, 0.451, NNE G29 EVEREST ELECTRONIC 2100 ORANGEWOOD LUST Lower 1923, 0.364, West G28 EVEREST ELECTRONIC 2100 ORANGEWOOD LUST, HIST CORTESE Lower 1923, 0.364, West G27 GATEWAY APARTMENTS I 2020,2034,2040 & 210 ENVIROSTOR, VCP Lower 1923, 0.364, West 26 PINATA MEXICAN FOODS 2125 E ORANGEWOOD AV LUST, SWEEPS UST, HIST UST, CA FID UST, EMI, HIST... Lower 1871, 0.354, WNW F25 ARMORED TRANSPORT 1602 ORANGE GROVE AV LUST, HIST CORTESE Higher 1777, 0.337, East F24 ARMORED TRANSPORT 1602 W ORANGE GROVE LUST Higher 1777, 0.337, East F23 DATA CIRCUITS 1607 E ORANGE GROVE SEMS Higher 1722, 0.326, East F22 DATA CIRCUITS INC 1607 W ORANGE GROVE CORRACTS, RCRA-TSDF, RCRA-SQG Higher 1722, 0.326, East F21 DATA CIRCUITS INC. 1607 WEST ORANGEGROV ENVIROSTOR Higher 1722, 0.326, East F20 DATA CIRCUITSINC. 1607 W ORANGE GROVE ENVIROSTOR, Orange Co. Industrial Site, HWP Higher 1722, 0.326, East F19 STEVENS METAL FINISH 1607 W ORANGE GROVE RCRA-LQG, ENVIROSTOR Higher 1722, 0.326, East E18 PACIFIC FINISHING IN 760 N ECKHOFF ST RCRA-SQG, FINDS, ECHO Higher 1292, 0.245, NE E17 NATIONAL OILWELL VAR 759 ECKHOFF ST. RCRA-LQG, EMI, NPDES Higher 1268, 0.240, NE 16 SERVICE MANUFACTURIN 2230 SOUTH DUPONT DR RCRA-SQG, FINDS, ECHO Lower 1171, 0.222, WSW D15 KARCHER ENVIRONMENTA 2300 E. ORANGEWOOD A HWT Lower 1034, 0.196, West D14 SANHER WIRE WHEEL IN 2300 E ORANGEWOOD RCRA-SQG, FINDS, ECHO Lower 1034, 0.196, West C13 HANDCRAFTED METAL 675 N ECKHOFF UNIT F RCRA-SQG Higher 1002, 0.190, ENE C12 TOM MC EWEN RACING 675 N ECKOFF ST UNIT RCRA-SQG, FINDS, ECHO Higher 1002, 0.190, ENE C11 DANS MACHINE TOOL RE 675 N ECKHOFF STE F RCRA-SQG, FINDS, ECHO Higher 1002, 0.190, ENE C10 YELLOW FREIGHT SYSTE 700 ECKHOFF STREET N SLIC Higher 950, 0.180, ENE C9 YELLOW FREIGHT SYSTE 700 N ECHOFF SWEEPS UST Higher 950, 0.180, ENE B8 YELLOW FREIGHT SYSTE 700 N ECKHOFF ST RCRA-SQG, SLIC, HIST UST, CA FID UST, CHMIRS,... Higher 842, 0.159, NE B7 YRC, INC (896) 700 N ECKHOFF ST UST Higher 842, 0.159, NE 6 LA LINDA PLAZA 1926 W ORANGEWOOD AV HIST UST Higher 730, 0.138, East A5 ANAHEIM FIRE TRAININ 2400 E ORANGEWOOD AV SWEEPS UST, CA FID UST, EMI Lower 305, 0.058, WSW A4 2400 E ORANGEWOOD AV AST Lower 305, 0.058, WSW
A3 FIRE STATION TRAININ 2400 E ORANGEWOOD AV HIST UST Lower 305, 0.058, WSW A2 FIRE STATION TRAININ 2400 EAST ORNAGEWOOD HIST UST Lower 305, 0.058, WSW 1 CAREMARK INFANT CARE 2211 W. ORANGEWOOD A UST Higher 211, 0.040, ENE